Robert Walker v. K. Drake Ozment, 21-12114

Robert Walker and Tamiko Peele, proceeding pro se, appealed a district-court order denying their motion for a “temporary injunction” (also seeking a stay and other relief) in their Chapter 13 bankruptcy matter.
This Court previously dismissed appeal of the stay portion as not appealable; the panel here considered whether it had jurisdiction over the claimed injunction denial.
The debtors sought (1) turnover/return of property and records from their former counsel Ozment/Ozment Law and cessation of collection, (2) cessation of certain third-party insurance/tax payments and return of funds, and (3) cessation of asset disposition and return of property.
The Court held it had interlocutory jurisdiction under 28 U.S.C. § 1292(a)(1) because the district court denied injunctive relief; the appeal was not moot because some requests (e.g., turnover of former-counsel records) were collateral and could receive effectual relief despite the Chapter 13 dismissal.
On the merits, the Court affirmed: debtors abandoned any challenge to the district court’s exercise of discretion by failing to brief abuse-of-discretion arguments; separate motions (fees, leave to file) were denied for lack of entitlement, specification, or compliance with procedural orders.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction to hear appeal of injunction denial	Walker/Peele asserted district court wrongly denied their “temporary injunction.”	Appellees implied portions (like a stay) were not appealable; jurisdiction disputed.	Court has interlocutory jurisdiction under 28 U.S.C. § 1292(a)(1) over denial of injunctive relief.
Mootness after Chapter 13 dismissal	Debtors argued appeal remains because relief (e.g., turnover) could still be granted.	Appellees argued dismissal moots appeal.	Not moot: dismissal only moots appeals that make relief impossible; collateral requests can survive dismissal.
Merits — whether injunction denial was reversible (abuse of discretion)	Debtors sought injunctive relief but offered few legal arguments on abuse of discretion.	District court’s denial was within its discretion.	Debtors abandoned the abuse-of-discretion claim by failing to brief it; affirmed.
Motions for fees and to file unspecified oversized filing	Debtors sought fees and leave to file an unspecified oversized document.	Appellees opposed; Court noted procedural noncompliance and lack of entitlement.	Denied: fees unavailable under Chambers factors; leave denied as unspecified; other motions denied for noncompliance.

Erickson v. Pardus, 551 U.S. 89 (2007) (pro se filings must be liberally construed)
Neidich v. Salas, 783 F.3d 1215 (11th Cir. 2015) (Chapter 13 dismissal moots appeals only when relief becomes impossible)
In re Tucker, [citation="743 F. App'x 964"] (11th Cir. 2018) (collateral challenges survive Chapter 13 dismissal)
Delta Air Lines, Inc. v. Air Line Pilots Ass'n, Int'l, 238 F.3d 1300 (11th Cir. 2001) (abuse-of-discretion standard for reviewing denial of preliminary injunction)
Sapuppo v. Allstate Floridian Ins. Co., 739 F.3d 678 (11th Cir. 2014) (issues not briefed on appeal are abandoned)
Timson v. Sampson, 518 F.3d 870 (11th Cir. 2008) (pro se litigants also abandon issues not raised on appeal)
Chambers v. NASCO, Inc., 501 U.S. 32 (1991) (narrow circumstances for federal courts to assess attorney’s fees under inherent power)