Strawn v. Sonneveld

Summary

The United States District Court for the Eastern District of California denied Melissa Anne Strawn’s ex parte motion for a temporary restraining order seeking to prevent enforcement of a Washington state custody and dissolution judgment. The court held that the action was an impermissible de facto appeal barred by the Rooker-Feldman doctrine because plaintiff challenged alleged errors in the state proceedings and sought relief from the state judgment.

Holdings

1. The action was a forbidden de facto appeal because plaintiff complained of legal errors allegedly committed by the Washington state court and sought relief from that court's judgment.
2. Plaintiff was not entitled to a temporary restraining order because the Rooker-Feldman doctrine barred the federal court from exercising jurisdiction and plaintiff therefore failed to demonstrate even serious questions going to the merits.

Questions Presented

1. Whether plaintiff was entitled to a temporary restraining order prohibiting enforcement of the Washington state court dissolution and custody judgment.
2. Whether the Rooker-Feldman doctrine barred the federal court from exercising jurisdiction over plaintiff's claims because they constituted a de facto appeal from a state court judgment.

Disposition

other