Lockey v. Wilmington Savings Fund Society, FSB
4:25-cv-00367
E.D. Tex.May 2, 2025Background
- Plaintiffs David R. Lockey and Kylene Lockey filed suit in state court to set aside a foreclosure sale of their property.
- The case was removed to federal court and assigned to a Magistrate Judge under 28 U.S.C. § 636.
- Plaintiffs sought a temporary restraining order and/or preliminary injunction to prevent Defendants from enforcing a state court judgment related to possession of the property (forcible detainer/eviction).
- The Magistrate Judge recommended denying the injunction due to federal court jurisdiction limits under the Anti-Injunction Act.
- Plaintiffs objected to the Magistrate Judge’s report, arguing the Act did not apply and that they met the requirements for injunctive relief.
- The District Court conducted a de novo review, adopted the Magistrate Judge’s report, and denied the requested injunctive relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the Anti-Injunction Act bar the federal court from granting injunctive relief against state court eviction proceedings? | The Act does not bar relief; the case meets an exception. | The Act bars this relief. | The Act applies; court cannot enjoin state proceedings. |
| Have Plaintiffs shown a likelihood of success and met standards for preliminary injunctive relief? | Plaintiffs alleged due process violations and foreclosure irregularities. | Plaintiffs did not meet the standard. | Plaintiffs failed to meet requirements for injunctive relief. |
| Are Plaintiffs' objections to the Magistrate Judge’s findings meritorious? | Plaintiffs renewed prior arguments and objected to the Report. | Report's findings are correct. | Objections overruled as they lack merit. |
| Should the Magistrate Judge’s Report and Recommendation be adopted? | Plaintiffs objected and sought to overturn. | Support adoption. | Report is adopted; Plaintiffs' injunction motion is denied. |
Key Cases Cited
- Knoles v. Wells Fargo Bank, N.A., [citation="513 Fed. App'x 414"] (5th Cir. 2013) (injunctive relief cannot enjoin enforcement of valid Texas court judgment under the Anti-Injunction Act)
- Douglass v. United Servs. Auto. Ass’n, 79 F.3d 1415 (5th Cir. 1996) (de novo review standard for magistrate judge’s report and recommendations)
- Janvey v. Alguire, 647 F.3d 585 (5th Cir. 2011) (elements for preliminary injunctive relief)