Kendrick Simpson v. Christe Quick, et al.

Summary

The United States District Court for the Western District of Oklahoma denied Kendrick Simpson’s motion for a preliminary injunction seeking to prevent his execution while he appealed the dismissal of his 42 U.S.C. § 1983 action. The court held that it lacked jurisdiction under the Rooker-Feldman doctrine and Eleventh Amendment immunity and alternatively determined that Simpson had not shown a likelihood of success on appeal or satisfied the requirements for injunctive relief.

Holdings

1. A district court that lacks jurisdiction over the plaintiff's underlying claims under the Rooker-Feldman doctrine and Eleventh Amendment immunity also lacks jurisdiction to direct the same defendants' conduct through an injunction pending appeal.
2. Simpson failed to establish a substantial likelihood of success on appeal because he did not explain how the district court could reach the merits despite the jurisdictional rulings under Rooker-Feldman and Eleventh Amendment immunity.
3. A movant seeking injunctive relief pending appeal must show a likelihood of success on the merits; irreparable harm cannot independently justify relief by relaxing that requirement.

Questions Presented

1. Whether the district court had jurisdiction to enjoin defendants from executing Simpson while his appeal from the dismissal of his § 1983 action was pending.
2. Whether Simpson satisfied the requirements for an injunction pending appeal, including a substantial likelihood of success on the merits.

Disposition

other