Randy Ramgoolam, a Canadian who became a U.S. permanent resident in 2021, sued his ex-wife Ritu Gupta in 2024 seeking financial support under an Affidavit of Support she signed for his immigration application. Gupta, an American physician, had promised in the affidavit to ensure Ramgoolam's income stayed above 125% of the federal poverty line. The couple divorced in Michigan in 2022 with a settlement stating neither would pay spousal support, but Ramgoolam later claimed his income fell below the poverty threshold and demanded support.
Chief Judge Jeffrey Sutton rejected Ramgoolam's argument that federal immigration law preempts state claim preclusion rules, writing that "Federal statutes do not 'preempt' other federal statutes." The court ruled that the Full Faith and Credit Act requires federal courts to apply state preclusion law, and that Michigan's "broad res judicata rule" bars claims that "could have been" resolved in prior proceedings. Sutton noted that immigrants have successfully raised Affidavit of Support enforcement claims in divorce proceedings across the country, including in Michigan.
The Eastern District of Michigan had dismissed Ramgoolam's case in 2024, finding that the divorce judgment precluded his claim. The district court rejected Gupta's argument that Rooker-Feldman doctrine barred jurisdiction but agreed that Michigan's claim preclusion law applied. Ramgoolam appealed, arguing federal preemption should override state preclusion rules.
The ruling clarifies that immigration-related financial obligations created by federal Affidavits of Support remain subject to traditional claim preclusion principles when enforcement actions could have been brought in state divorce proceedings. The decision reinforces the broad scope of Michigan's res judicata rule and demonstrates how federal immigration law interacts with state civil procedure in family law contexts.