Johnson v. GigSmart, Inc.
- 3:24-cv-02233
- U.S. District Court · Northern District of California
- 2
In Johnson v. GigSmart, Inc., the court, with no judge named, ordered filings about jurisdiction before considering Johnson’s temporary-restraining-order request.
Susan Johnson and the other plaintiffs, and GigSmart, Inc.; the order also required information about the related state-court action.
What happened
Susan Johnson and other plaintiffs asked the court to temporarily stop GigSmart, Inc. from taking an unspecified action and requested a hearing about a preliminary injunction. The plaintiffs served GigSmart on April 22, 2024.
The court questioned whether it had jurisdiction to review a state-court judgment. It explained that federal district courts generally cannot act as appellate courts over final state-court judgments, but that this rule is narrow. The court ordered the parties to explain the status of the related state-court action and whether that rule applied.
The court ordered GigSmart to file an opposition or statement of non-opposition to the motion and to explain why its opposition was late; it also allowed a reply if an opposition was filed. The court scheduled a videoconference hearing for April 24, 2024, and further proceedings for April 30, 2024, if it retained jurisdiction. The court, whose judge was not named in the opinion, did not decide the temporary restraining order.
The detailed version
- Johnson v. GigSmart, Inc. · No. 3:24-cv-02233
- Apr. 23, 2024
Background
The plaintiffs filed an ex parte motion for a temporary restraining order and for an order setting a hearing on a preliminary injunction. The opinion states that the plaintiffs served GigSmart on April 22, 2024, and that GigSmart had not filed an opposition or statement of non-opposition as of the order. Under the cited local rule, GigSmart’s opposition was due by April 24, 2024, at 11 a.m.
Jurisdictional Concern
Before addressing the requested temporary restraining order, the court examined whether it had subject-matter jurisdiction to review a state-court judgment. The court discussed the Rooker-Feldman doctrine, which generally prevents federal district courts from reviewing final judgments entered by state courts. The court also explained that the doctrine is narrow and applies to cases brought by state-court losers who claim injuries caused by state-court judgments issued before the federal case began and who ask the federal court to review and reject those judgments.
The court ordered each party to state the status of the related state-court action, identified by case number 24-CV-066123 in the Alameda County Superior Court, and to explain whether the Rooker-Feldman doctrine applied given that action’s procedural posture.
Order
The court ordered GigSmart, by April 24, 2024, to file an opposition or statement of non-opposition to the pending motion and to respond to the order to show cause by explaining why its opposition was not timely filed. If GigSmart filed an opposition, it could file a reply by April 24, 2024, no later than 11 a.m. The court scheduled a videoconference hearing on the temporary restraining-order application for April 24, 2024. It also placed the matter on the calendar for further in-person proceedings on April 30, 2024, if the court retained jurisdiction. The opinion does not grant or deny the temporary restraining-order motion and does not name the district judge.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.