Brower v. Quatch, 2:25-cv-00687

Plaintiff David S. Brower filed suit against Danielle T.T. Quatch, others, and later added additional defendants, including a judge and the Washington State Bar Association.
Brower claimed various state and federal law violations related to alleged misconduct in divorce and bankruptcy proceedings.
The original complaint was dismissed for lack of jurisdiction and failure to state a claim, with leave to amend.
In his amended complaint, Brower sought preliminary injunctive relief, a declaration that certain state court orders were void, and the disqualification of the presiding judge.
The court reviewed the amended complaint pursuant to mandatory screening under 28 U.S.C. § 1915(e)(2)(B) for cases filed by plaintiffs proceeding in forma pauperis (IFP).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Private right to sue under criminal statutes	Defendants violated RCW 9A.36.060 and 18 U.S.C. § 1519	Statutes do not provide private cause of action	No private cause of action; claims dismissed
Preliminary injunction	Needed to stop enforcement of void state orders and prevent harm	Not met; insufficient merits shown	No likelihood of success; injunction denied
Voiding state court orders	State court orders void due to due process and jurisdictional violations	Not challenged	Federal court lacks jurisdiction to void state orders
Judicial disqualification	Judge's continued involvement creates appearance of bias	Not challenged	Motion to disqualify denied

Calhoun v. Stahl, 254 F.3d 845 (9th Cir. 2001) (explaining that IFP dismissal review requirements apply to all plaintiffs, not just prisoners)
Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008) (establishing four-factor test for preliminary injunctions)
Garcia v. Google, Inc., 786 F.3d 733 (9th Cir. 2015) (explains likelihood of success as threshold issue for injunctions)
Noel v. Hall, 341 F.3d 1148 (9th Cir. 2003) (federal courts lack jurisdiction to review state court decisions)