Summary
This Report and Recommendation addresses Tyler C. Martel’s emergency motion for a temporary restraining order or preliminary injunction concerning a New Hampshire family-court child-support order. The magistrate judge recommends denying relief based on judicial immunity and Younger abstention, and notes that the motion also failed to satisfy Federal Rule of Civil Procedure 65(b).
Court
United States District Court for the District of New Hampshire
Jurisdiction
United States District Court for the District of New Hampshire
Decision date
May 4, 2026
Docket number
26-cv-326-LM-TSM
Disposition
other
Questions Presented
- Whether Martel was entitled to a temporary restraining order or preliminary injunction under the four-factor injunctive-relief standard.
- Whether absolute judicial immunity barred claims against the state family-court judge based on issuance and contents of the child-support order.
- Whether Younger abstention required the federal court to refrain from granting injunctive or declaratory relief that would interfere with the ongoing New Hampshire family-court proceedings.
Holdings
- Martel was not entitled to temporary or preliminary injunctive relief because he could not establish a likelihood of success on the merits, and the motion also failed to comply with the ex parte requirements of Federal Rule of Civil Procedure 65(b).
- Judge Prevett was entitled to absolute judicial immunity from Martel's claims based on issuing and determining the contents of the March 31 family-court order.
- The federal court should abstain under Younger from granting injunctive or declaratory relief that would interfere with Martel's ongoing New Hampshire family-court proceedings.
Court Document
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