2:25-cv-01809
E.D. Cal.Jul 2, 2025Background
- Plaintiff Melissa Anne Strawn, proceeding pro se, sought a temporary restraining order (TRO) against defendant Jord Sonneveld.
- Strawn challenged a June 18, 2025, King County, Washington state court judgment granting Sonneveld sole custody of their three minor children and ordering the sale of Strawn’s California home.
- Strawn alleged the Washington orders were obtained based on fraudulent representations by Sonneveld and his counsel and during her medically documented incapacity, which was disregarded by the state court.
- The judgment allegedly authorized Sonneveld to enter Strawn’s home, in violation of an existing Washington Domestic Violence Protection Order.
- Strawn asserted claims under federal constitutional and statutory law, including due process, the Violence Against Women Act, the Parental Kidnapping Prevention Act, and the ADA, seeking, among other relief, to enjoin enforcement of the Washington judgment.
- The federal court was asked to grant a TRO preventing enforcement of the state court judgment while state appeals proceeded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Federal district court jurisdiction over state court judgments (Rooker-Feldman) | Federal court can grant relief from unfair/unconstitutional state judgment | Rooker-Feldman bars federal review of state court decisions | Court lacks jurisdiction under Rooker-Feldman doctrine |
| Likelihood of success on the merits for TRO/preliminary injunction | Serious federal questions warrant injunctive relief | No jurisdiction; standard not met | Plaintiff fails to show likelihood of success |
| Immediate irreparable harm | Enforcement of state judgment violates rights and causes harm | Legal remedy must come from state appeals, not federal court | Not established; remedy lies in state court |
| Injunctive relief to stay enforcement of state family law judgment | Federal court can preserve status quo | Federal courts cannot enjoin state court judgments (esp. in family law) | Injunction/TRO denied; relief inappropriate |
Key Cases Cited
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp, 544 U.S. 280 (Rooker-Feldman bars federal courts from reviewing state court judgments)
- Noel v. Hall, 341 F.3d 1148 (Rooker-Feldman doctrine precludes de facto appeals of state court decisions by federal courts)
- Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (lays out four-factor test for injunctive relief)
- Stuhlbarg Int’l Sales Co. v. John D. Brush & Co., 240 F.3d 832 (standards for preliminary injunction and TRO are substantially identical)
- Stormans, Inc. v. Selecky, 586 F.3d 1109 (recites standards for preliminary injunctive relief in the Ninth Circuit)