MacKie v. Truckee Carson Irrigation District
3:16-cv-00031
D. Nev.Feb 5, 2016Background
- Plaintiffs Stuart and Susan Mackie allege TCID breached a water-delivery contract, causing $4.3 million in damages.
- Plaintiffs filed financing statements with the Nevada Secretary of State asserting a perfected claim for those damages.
- TCID sued the Mackies in state court and obtained an ex parte restraining order allowing termination of those financing statements and enjoining further filings.
- Plaintiffs removed/commenced federal litigation and moved for an ex parte TRO and preliminary injunction to enjoin enforcement of the state-court order. The Motions were identical.
- Plaintiffs argued they were not properly served, TCID’s attorneys were not licensed, and the state judge lacked qualification because he did not place certain election/oath/bond documents on the record.
- The district court denied the ex parte TRO and preliminary injunction for failure to show good cause for ex parte relief and because the Rooker–Feldman doctrine bars federal review of the state-court decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ex parte TRO appropriate | Mackie argued immediate relief was needed to prevent termination of financing statements | TCID implicitly argued normal adversarial process should proceed; no good-cause shown for ex parte relief | Denied — plaintiffs failed to show good cause or meet Rule 65(b) requirements for ex parte relief |
| Service and procedural defects | Mackie contended they were not properly served | TCID relied on state-court process and orders | Not decided on merits — federal court refused to entertain because of Rooker–Feldman |
| Counsel licensing challenge | Mackie asserted TCID’s attorneys were not licensed to practice | TCID maintained validity of state proceedings and counsel authority | Rejected for federal review — claims are efforts to undo state-court judgment and thus barred |
| Judge qualification challenge | Mackie claimed state judge lacked qualification for failing to place election/oath/bond in record | TCID relied on validity of state-court order | Denied — federal court cannot review/state-judge-qualification claim because it would require reversing state-court judgment (Rooker–Feldman) |
Key Cases Cited
- Winter v. Natural Res. Def. Council, 555 U.S. 7 (TRO/preliminary injunction standard requiring likelihood of success and irreparable harm)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (federal district courts lack jurisdiction to review state-court judgments)
- D.C. Court of Appeals v. Feldman, 460 U.S. 462 (reinforcing limits on federal review of state-court judgments)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (Rooker–Feldman confined to cases that are de facto appeals)
- Doe v. Mann, 415 F.3d 1038 (9th Cir.) (federal court must refuse to hear claims that are de facto appeals and those inextricably intertwined)
- Noel v. Hall, 341 F.3d 1148 (9th Cir.) (discussing inextricably intertwined doctrine)
- Earth Island Inst. v. Carlton, 626 F.3d 462 (9th Cir.) (preliminary injunction standards in Ninth Circuit)