Anna M. Murphy v. Charley D. Smith et al.

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.

Holdings

1. 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.
2. 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.

Questions Presented

1. 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.
2. 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.

Disposition

denied