Bucknor v. County of Contra Costa
- Alex Tse
- 3:26-cv-08460
- U.S. District Court · Northern District of California
- 1
In Don Bucknor v. County of Contra Costa, Judge Rita F. Lin denied emergency relief and ordered Bucknor to explain why the case should not be dismissed.
Don Bucknor and the defendants in his federal action, including the County of Contra Costa; the order also concerns the federal court’s ability to review the state-court custody proceedings described in the opinion.
What happened
In Don Bucknor v. County of Contra Costa, Don Bucknor challenged state-court orders concerning physical custody of his daughter.
The court said federal courts cannot review state-court child-custody proceedings. It therefore found that Bucknor had not shown a sufficient chance of success or a serious issue supporting emergency relief.
Judge Rita F. Lin denied Bucknor’s request for a temporary restraining order. She also ordered Bucknor to explain in writing by September 16, 2026, why the case should not be dismissed for lack of subject-matter jurisdiction.
The detailed version
- Bucknor v. County of Contra Costa · No. 3:26-cv-08460
- Alex Tse
- Aug. 17, 2026
Background
Don Bucknor alleged that a state-court judge issued an order depriving him of physical custody of his daughter. The court understood the action as challenging that order and later state-court orders concerning custody.
Court’s analysis
The court held that the Rooker-Feldman doctrine prevents federal courts from reviewing state-court child-custody proceedings. Because of that jurisdictional problem, the court concluded that Bucknor had not shown either a likelihood of success on the merits or a serious question going to the merits, which are requirements for the requested emergency relief.
Ruling
Judge Rita F. Lin denied Plaintiff’s request for entry of a temporary restraining order. The court also ordered Plaintiff to show cause, in writing, by September 16, 2026, why the action should not be dismissed for lack of subject-matter jurisdiction. The opinion did not dismiss the action in this order.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.