Knoles v. Wells Fargo presented a rare encounter between an eviction and the Rooker-Feldman doctrine. No. 12-40369 (Feb. 19, 2013, unpublished). The borrower lost a forcible entry & detainer (eviction) matter at trial in JP court and on appeal. The borrower then sued for damages, Wells removed, and the borrower unsuccessfully tried to get a TRO about possession from the federal district court. The district court denied relief based on the Rooker-Feldman doctrine about federal review of final state court judgments. The Fifth Circuit found that it had jurisdiction over the interlocutory appeal pursuant to 28 U.S.C. § 1292(a)(1), even though the appeal was nominally from a TRO, because the relief at issue was “more in the nature of a temporary injunction in fact, though not in name.” The court deflected an argument about mootness to hold that the order sought a federal injunction against a final state court judgment in violation of the Anti-Injunction Act.
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