Doe v. Larsen
- Garnett
- 1:25-cv-06020
- U.S. District Court · Southern District of New York
- 1
In Jane Doe v. Christian Larsen, Judge Garnett denied Doe’s motion to stop a California state proceeding because she failed to show entitlement to extraordinary relief.
Jane Doe, who sought to halt the California state-court proceeding; Christian Larsen and the other defendants in this action; and the pending California proceeding concerning whether Doe is a vexatious litigant.
What happened
In Jane Doe v. Christian Larsen, Jane Doe brought a civil-rights lawsuit under Section 1983, alleging that the defendants were using court proceedings to retaliate against her for cooperating with federal authorities. She asked the court to stop a pending California proceeding about whether she should be labeled a vexatious litigant.
The court explained that a preliminary injunction is an extraordinary remedy requiring, among other things, a showing of likely success, irreparable harm, and that an injunction would serve the public interest. The court said Doe had not shown how the California proceeding, including any possible bond requirement, would affect her ability to pursue this case in New York. She also had not shown a basis for the court to control proceedings in a California state court.
Judge Garnett denied the motion and directed the Clerk of Court to terminate the motion from the docket. The opinion did not decide the underlying Section 1983 allegations.
The detailed version
- Doe v. Larsen · No. 1:25-cv-06020
- Garnett
- Oct. 30, 2025
Background
Jane Doe brought this Section 1983 action, a civil-rights action under federal law. She alleged that the defendants were using judicial proceedings to retaliate against her for cooperating with federal authorities.
On October 21, 2025, Doe moved for a temporary restraining order and preliminary injunction. She sought an order preventing a pending California state-court proceeding concerning whether she is a “vexatious litigant.”
Legal standard
The court described a preliminary injunction as an “extraordinary” remedy. It stated that Doe had to show, among other things, that she was likely to succeed on the merits, would suffer irreparable harm without court intervention, that the injunction could prevent the identified harm, and that issuing the injunction would serve the public interest.
Court’s analysis
The court held that Doe had “utterly failed” to show how anything occurring in the California proceeding—including a possible requirement that she post a bond to continue that proceeding—would affect her ability to pursue her claims in this New York action. The court also held that she had not demonstrated any basis for exercising authority over the California state-court proceedings.
Disposition
The motion was DENIED. The Clerk of Court was directed to terminate Docket No. 17. The opinion did not decide the underlying Section 1983 allegations.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.