Dingle v. Armstrong
2:23-cv-04141
| D.S.C. | Jan 29, 2024Background
- Eugene Dingle sought a preliminary injunction against Leslie Armstrong and Time Mose related to a family court matter.
- The Magistrate Judge recommended denial of Dingle’s motion, noting the motion was premature as defendants had not yet been served and had received no notice.
- Dingle objected, arguing improper referral to the Magistrate, and claimed he had complied with all steps for service.
- He also argued the need for injunctive relief to avoid purported irreparable harm, such as incarceration and job loss, and asserted federal court jurisdiction due to constitutional claims.
- The District Court performed a de novo review of the objections and upheld the Magistrate Judge’s findings, applying the standard from Winter v. NRDC.
- The court ultimately denied the motion for preliminary injunction, citing lack of jurisdiction, no likelihood of success, and failure to clearly show any of the Winter factors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Appropriateness of Magistrate Jurisdiction | Dingle did not consent under Rule 73(b) and 28 U.S.C. § 636(c) | not discussed (not served) | Referral was proper under automatic review rules |
| Prematurity and Notice of Injunction Motion | Dingle claimed he fulfilled all requirements for notice/service | not discussed | Motion was premature; defendants hadn’t been served/notice |
| Federal Court Jurisdiction over State Matters | Federal courts have power for general constitutional challenges | not discussed | No jurisdiction; Rooker-Feldman doctrine bars review |
| Preliminary Injunction – Winter Factors | Faces irreparable harm; balance, public interest in favor | not discussed | No clear showing on any Winter factor; relief denied |
Key Cases Cited
- Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (U.S. 2008) (sets standard for preliminary injunctions: likelihood of success, irreparable harm, balance of equities, public interest)
- Mathews v. Weber, 423 U.S. 261 (U.S. 1976) (clarifies the limited role of a magistrate judge’s recommendations)
- Davani v. Virginia Dep’t of Transp., 434 F.3d 712 (4th Cir. 2006) (explains the Rooker-Feldman doctrine limits federal review of state court decisions)
- Casey v. Hurley, 671 F. App’x 137 (4th Cir. 2016) (reaffirms lack of federal jurisdiction over state court appeals under Rooker-Feldman)