Whether a federal court may apply state claim preclusion rules to federal Affidavits of Support made as part of a U.S. residency application; 8 USC § 1183a(e); The Full Faith & Credit Act (FFCA); Whether the district court correctly applied Michigan’s claim preclusion principles; The district court’s jurisdiction over plaintiff’s claim for support; Applicability of Rooker v Fidelity Trust Co & District of Columbia Court of Appeals v Feldman

[This appeal was from the ED-MI.] The district court correctly applied Michigan’s claim preclusion rules in concluding that the parties’ divorce judgment precluded plaintiff-Ramgoolam’s claim for financial support from defendant-Gupta (his ex-wife) based on the Affidavit of Support filed during Ramgoolam’s residency proceedings. Gupta, an American, married Ramgoolam, a Canadian, in 2017. Ramgoolam later applied for U.S. residency. In support of that application, Gupta signed an Affidavit of Support, in which she committed to ensure that Ramgoolam’s yearly income remained above 125% of the federal poverty line. If she failed to do so, § 1183a(e) empowered him to sue her for support. His application was approved but the parties divorced in Michigan in 2022. The divorce settlement specified neither would pay spousal support and contained a mutual release of all claims or potential claims. In 2024, Ramgoolam filed this suit, seeking to have Gupta support him because his income no longer met the mark set in the Affidavit. The district court dismissed the case based on the divorce judgment. On appeal, the court first determined that Rooker and Feldman did not bar the district court from having jurisdiction. Turning to Ramgoolam's arguments, the court held that a federal court may apply state claim preclusion rules to federal Affidavits of Support. The FFCA “requires federal courts to give a state court’s judgments the same preclusive effect they would enjoy under that State’s law.” In this case, determining “whether the Michigan divorce judgment barred Ramgoolam’s federal lawsuit thus required the district court to apply Michigan claim preclusion law.” The fact that “the Affidavit of Support is a creature of federal law” did not change things. The court rejected Ramgoolam’s federal preemption argument, holding that Gupta’s preclusion defense originated in federal law – the FFCA. Even though the Affidavit provided that the obligation survived divorce, Gupta’s claim-preclusion defense did not arise from the divorce but “from Ramgoolam’s failure to raise his enforcement claim before or during the divorce proceedings.” The court also held that the district court properly applied Michigan law. The parties only disputed the third element of Michigan’s res judicata rule, and “Ramgoolam could have brought his claim before the Michigan family court.” Affirmed.