HPIL HOLDING, INC. v. HARRY ZHANG aka Haining Zhang; STEPHEN BROWN; ANGELA COLLETTE; DAVID POSTULA; BROWN FAMILY INVESTMENTS, LTD.; CRANK MEDIA, INC. - Articles

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HPIL HOLDING, INC. v. HARRY ZHANG aka Haining Zhang; STEPHEN BROWN; ANGELA COLLETTE; DAVID POSTULA; BROWN FAMILY INVESTMENTS, LTD.; CRANK MEDIA, INC.

Posted by: Azya Thornton on Mar 6, 2026

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ON BRIEF: J. Lehman, THE LAW OFFICES OF DANIEL J. LEHMAN, Farmington Hills, Michigan, for Appellant.

Attorneys 2: ON BRIEF: Devin W. Bone, PAESANO AKKASHIAN, PC, Bloomfield Hills, Michigan, for Appellees Zhang and Collette.

Attorneys 3: ON BRIEF: Dean Elliott, DEAN ELLIOTT, PLC, Royal Oak, Michigan, for Appellee Brown.

Judge(s): SUTTON, Chief Judge; LARSEN and DAVIS, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Michigan at Bay City

SUTTON, Chief Judge. Minority shareholders of HPIL Holding, a Wyoming corporation, successfully petitioned a state court for the appointment of a receiver. Three years later, HPIL filed this lawsuit alleging that the minority shareholders looted the corporation during the receivership proceeding. Pointing to the state-court order that appointed the receiver, the district court dismissed the lawsuit for lack of subject-matter jurisdiction under 28 U.S.C. § 1257(a), which permits disappointed state-court litigants to seek review of state-court decisions in the United States Supreme Court but does not permit them to appeal such decisions to a federal district court. See Rooker v. Fid. Tr. Co., 263 U.S. 413, 416 (1923); Dist. of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 463 (1983). Because HPIL did not purport to seek a writ of certiorari or otherwise appeal the state-court appointment of a receiver, because the implied and vanishingly narrow jurisdictional bar under § 1257(a) does not apply, and because the bar does not displace the customary way that federal courts respect prior state court rulings (issue and claim preclusion), we reverse.

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