Case Update (2 April 2026): Ramgoolam v. Gupta; Ex-Spouse precluded from raising claim under Affidavit of Support
The parties are former spouses, divorced in Michigan in 2022. The former Husband was Canadian, and after moving to the United States, sought legal permanent residency. His former Wife signed an Affidavit of Support, committing to ensure that her now ex-Husband’s income remained above 125% of the federal poverty line each year. The Husband’s residency application was approved in February 2021. The parties’ marital settlement agreement was incorporated into their divorce judgment, and purported to “resolve all issues arising out of the parties’ marriage” which included, “alimony/spousal support, property division, custody, parenting time, child support, attorney fees, taxes, and other related issues.” The judgment also specifically stated that “neither party will pay spousal support to the other party.” In October 2024, the ex-Husband filed a federal lawsuit, claiming his income had fallen below the 125% federal poverty line over the previous three years, and demanded that his ex-Wife pay him the support obligated under the Affidavit of Support. The ex-Wife sought to dismiss his lawsuit, arguing claim preclusion and abstention. The district court dismissed the ex-Husband’s suit, finding that his claim was precluded. He thereafter appealed.
The Court of Appeals concluded that “[t]he Full Faith and Credit Act requires federal courts to give a state court’s judgments the same preclusive effect they would enjoy under that State’s law.” The district court would apply Michigan claim preclusion law to determine whether the Michigan divorce judgment barred his claim in federal court for money under the Affidavit of Support. The ex-Husband argued that federal law - the Immigration and Nationality Act - preempts the state’s claim-preclusion rules. The Court of Appeals, however, stated that federal preemption applies to state law, and the point is to enforce the Supremacy Clause. “When state and federal law conflict, federal law prevails.” “But state law incorporated by a federal statute becomes ‘a part of the federal statutory scheme, so it is federal law being given effect, not state law.’” The Court of Appeals made clear that the ex-Wife’s preclusion defense here originated in federal law, and federal statutes do not preempt other federal statutes. The ex-Husband squarely points to the text of the Affidavit of Support, which reads, “divorce does not terminate [their] obligations” under the Affidavit. But, as the Court of Appeals said, the Wife’s claim preclusion defense does not arise from the divorce. It arises from the Husband’s failure to raise his enforcement claim before or during the divorce proceedings. The parties here agree that the divorce action did not involve a request, by the Husband, to enforce his Affidavit of Support. On appeal, the parties disagreed as to whether he had the right to raise the Affidavit of Support in the Michigan family court. The Court of Appeals noted, however, that the INA permits immigrants to seek enforcement of the Affidavit in “any appropriate court.” It cited to various state-court divorce proceedings across the United States where a remedy under these Affidavits were raised.
Therefore, the Court of Appeals affirmed the dismissal of the ex-Husband’s suit to seek his claim under the Affidavit of Support.
