Moreau v. White

Moreau v. White · United States District Court, Eastern District of Texas, Sherman Division · January 24, 2025 · No. 4:24-cv-00857

Summary

This memorandum opinion and order from the U.S. District Court for the Eastern District of Texas addresses the Respondent’s emergency motion for a stay of judgment pending appeal in a Hague Convention child custody case. Applying the Fifth Circuit’s four-factor test, the Court finds that the Respondent has not demonstrated a likelihood of success on the merits, irreparable injury, or substantial harm to the opposing party, nor does the public interest favor a stay. Consequently, the Court denies the motion and allows the final judgment ordering the children's return to Canada to take effect.

Court
United States District Court, Eastern District of Texas, Sherman Division
Jurisdiction
United States District Court, Eastern District of Texas
Decision date
January 24, 2025
Docket number
4:24-cv-00857
Procedural posture
Emergency motion for stay pending appeal of final judgment
Precedential value
nonprecedential
Disposition
other

Topics

family lawappellate procedureappellate jurisdictionstandard of reviewcivil procedure

Practice areas

family lawappellate procedurecivil procedure

Questions Presented

  1. Whether the district court should grant a stay pending appeal of its final judgment under the Hague Convention.

Holdings

  1. The court denied the emergency motion for a stay pending appeal.

Key quotations

“A stay pending appeal is extraordinary relief for which [the movant] bear[s] a heavy burden.” (at 1)
“A stay is an intrusion into the ordinary processes of administration and judicial review, and accordingly is not a matter of right, even if irreparable injury might otherwise result to the appellant.” (at 1)

Factual background

The children were determined to be habitually resident in Canada. Respondent retained the children in Texas contrary to a court order, prompting the petitioner to seek return of the children to Canada under the Hague Convention.

Procedural history

The district court held a bench trial on December 16-17, 2024, entered Findings of Fact and Conclusions of Law and a Final Judgment on January 17, 2025. Respondent filed a notice of appeal on January 21, 2025, and an emergency motion for a stay on January 22, 2025. Petitioner responded on January 23, 2025. The court denied the motion.

Court Document

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