Claim preclusion found in guaranty suit

The case of Weaver v. Texas Capital Bank first presented a jurisdictional question under the Rooker-Feldman doctrine.  Texas Capital Bank had obtained a state court default judgment against a guarantor, and contended that the guarantor’s later adversary proceeding attacking the basis for that liability was an impermissible federal attack on a final state court judgment.  The Court disagreed, finding that Rooker-Feldman was not implicated.  Op. at 5-7.  The Court went on to reverse, however, finding that the guarantor’s arguments to the bankruptcy court were defenses to the earlier state court action and thus barred by claim preclusion.  Op. at 8-11.  The opinion thoroughly reviews Texas claim preclusion law and its “transactional” approach to the application of the compulsory counterclaim rule.

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