Summary
The United States District Court for the Eastern District of California denied Anna M. Murphy’s ex parte motion for a temporary restraining order seeking to enjoin a scheduled sheriff’s sale of residential properties. The court held that the motion was unduly delayed and that the requested relief was barred by the Rooker-Feldman doctrine because it constituted a de facto appeal from state-court judgments. The court therefore concluded that Murphy had not shown even serious questions going to the merits.
Topics
Practice areas
Questions Presented
- Whether the district court had jurisdiction to issue a temporary restraining order when plaintiff's claims challenged state-court rulings and sought to prevent enforcement of a state-court foreclosure judgment.
- Whether plaintiff satisfied the standards for ex parte temporary injunctive relief, including the requirements of Federal Rule of Civil Procedure 65(b)(1) and the applicable preliminary-injunction factors.
Holdings
- The district court lacked jurisdiction over plaintiff's motion because the federal action was a forbidden de facto appeal from state-court decisions: plaintiff alleged legal errors by the state court and sought to prevent enforcement of its foreclosure judgment.
- Plaintiff was not entitled to a temporary restraining order because the Rooker-Feldman doctrine deprived the court of jurisdiction and plaintiff failed to raise even serious questions going to the merits. The motion was also properly denied because plaintiff unduly delayed seeking ex parte relief despite having notice of the scheduled sale.
Key quotations
“The Rooker-Feldman doctrine prohibits federal district courts from hearing cases ‘brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.’” (Discussion)
“The proper legal standard for preliminary injunctive relief requires a party to demonstrate ‘that he is likely to succeed on the merits, that he is likely to suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in his favor, and that an injunction is in the public interest.’” (Legal Standard)
“Since plaintiff's suit is brought in this federal court as a forbidden de facto appeal from judicial decisions in the underlying state court action, this court need not reach the question of whether other issues are inextricably intertwined with an issue resolved by the state court in its judicial decision.” (Discussion)
Factual background
Plaintiff occupied and rented properties in Lincoln, California that were originally owned by defendant Charley Smith. The parties entered into a residential lease with an option to purchase and later a contract for deed; plaintiff allegedly fell behind on payments, and Smith obtained a state-court judgment authorizing judicial foreclosure. A sheriff's sale was scheduled for November 13, 2025, and plaintiff filed this federal action and sought a temporary restraining order on November 12, 2025, alleging that the state court had violated her property, due process, equal protection, and disability-accommodation rights.
Procedural history
Plaintiff alleged that prior Placer County Superior Court proceedings resulted in a judgment authorizing judicial foreclosure and a sheriff's sale. She then filed this federal action and sought a temporary restraining order shortly before the scheduled sale. The district court concluded that the requested relief constituted a forbidden de facto appeal from the state-court judgment under the Rooker-Feldman doctrine and also noted that plaintiff unduly delayed seeking ex parte relief.