JAFFAN INTERNATIONAL, LLC
v.
RADHE KRISHNA PROPERTIES, LLC, AND SHERIFF CHAD CHRONISTER, IN HIS OFFICIAL CAPACITY AS SHERIFF OF HILLSBOROUGH COUNTY
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The district court denied the plaintiff's motion for an injunction pending appeal because the Rooker-Feldman doctrine divested it of jurisdiction to review the plaintiff's challenge to a state court judgment, and denied the defendant's motion for sanctions without prejudice.
[1] The Rooker-Feldman doctrine strips federal district courts of subject matter jurisdiction over cases in which state-court losers seek relief based on injuries caused by s…
[2] A plaintiff cannot circumvent the Rooker-Feldman doctrine by recasting a state-court judgment challenge in different legal theories or arguments, as pretext is not tolera…
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Join FLexlaw to unlock all legal intelligence“The Rooker-Feldman doctrine applies to cases involving 'state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.'”
Establishes the foundational definition and scope of the Rooker-Feldman doctrine as a jurisdictional bar.
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Join FLexlaw to unlock all legal intelligencePlaintiff sought an injunction pending appeal after the district court denied its prior motion for a temporary restraining order and preliminary injun…
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Before the Court is Plaintiff Jaffan International, LLC's Emergency Motion for an Injunction Pending Appeal under Rule 62(d) and Defendant Radhe Krishna Properties, LLC's Motion for Sanctions against Plaintiff. (Docs. 28, 31). Plaintiffs motion arose out of this Court's denial of its Emergency Renewed Motion for Temporary Restraining Order and Preliminary Injunction based on the Rooker- Feldman doctrine (Doc. 25).
Plaintiff subsequently appealed the Court's Order to the Eleventh Circuit Court of Appeals (Doc. 27), and Plaintiff moved for an injunction pending appeal in both this Court and the Eleventh Circuit (Doc. 28; Emergency Motion for Administrative Injunction and Injunction Pending Appeal at 3–4, Jaffan Int'l, LLC v. Radhe Krishna Properties, LLC, No. 25-13943 (11th Cir. Nov. 10, 2025)). The Eleventh Circuit denied Plaintiffs emergency motion for an injunction due to
Plaintiff's failure to make the requisite showing. Order of the Court, Jaffan Int'l, LLC v. Radhe Krishna Properties, LLC, No. 25-13943 (11th Cir. Nov. 10, 2025). This Court then directed Defendants to respond to Plaintiffs motion (Doc. 30), and Defendants responded and sought sanctions against Plaintiff in that response. (Docs. 31, 32).
Upon careful review, Plaintiffs Emergency Motion for an Injunction Pending Appeal under Rule 62(d) is DENIED, and Defendant Radhe Krishna Properties, LLC's motion for Sanctions is DENIED without prejudice.
I.
Plaintiff's Emergency Motion for an Injunction Pending Appeal under Rule 62(d)
"[A] federal district court and a federal court of appeals should not attempt to assert jurisdiction over a case simultaneously.” Griggs v. Provident Consumer Discount Co., 459 U.S. 56, 58 (1982). Thus, filing a notice of appeal is "an event of jurisdictional significance—it confers jurisdiction on the court of appeals and divests the district court of its control over those aspects of the case involved in the appeal." Id. "[I]f a case ‘rests before the Court of Appeals,' the district court has no power to alter the status of the case.” Claiborne v. JP Morgan Chase Bank Nat'l Ass'n, 2025 WL 1262350, at *1 (11th Cir. May 1, 2025) (citation omitted). Nevertheless, the Federal Rules of Civil Procedure and Federal Rules of Appellate Procedure authorize both district courts and circuit courts to issue injunctions pending appeal. Fed. R. Civ. P. 62(d); Fed. R. App. P. 8(a)(2).
In evaluating whether an injunction pending appeal should be granted, courts consider four factors. Nken v. Holder, 556 U.S. 418, 426 (2009) (citing Hilton
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v. Braunskill, 481 U.S. 770, 776 (1987)). First, “whether the stay applicant has made a strong showing that he is likely to succeed on the merits." Id. Second, "whether the applicant will be irreparably injured absent a stay." Id. Third, "whether issuance of the stay will substantially injure the other parties interested in the proceeding." Id. And, fourth, “where the public interest lies.” Id.
Here, the Court need not venture beyond the first factor because Plaintiff has not made a strong showing that it is likely to succeed on the merits. The Rooker- Feldman doctrine applies to cases involving “state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments." Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005). In such cases, the district court cannot exercise subject matter jurisdiction because a district court's jurisdiction is original, not appellate. Id. at 283. The only proper federal venue for an appeal of the merits of a state court judgment is the United States Supreme Court. Behr v. Campbell, 8 F. 4th 1206, 1210 (11th Cir. 2021) (citing Exxon Mobil Corp., 544 U.S. at 283). Plaintiff is correct that Rooker- Feldman is a narrow doctrine. See id. at 1208. However, as the Eleventh Circuit has explained, “[a]lthough narrow in its application, a state court loser cannot avoid Rooker-Feldman's bar by cleverly cloaking [its] pleadings in the cloth of a different claim. Pretext is not tolerated.” May v. Morgan Cnty., Ga., 878 F. 3d 1001, 1005 (11th Cir. 2017) (emphasis altered).
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Here, Plaintiff attempts to cloak its state-court merits challenge. The writ of possesion that Plaintiff asked this Court to enjoin was the result of a state-court final judgment. (Doc. 24 at 10–11). That final judgment was affirmed by Florida's Second District Court of Appeal, and the United States Supreme Court denied certiorari. (Id. at 11). Now, in this action, Plaintiffs argument was that the execution of the writ should be enjoined because, according to Plaintiff, a denied liftstay motion from a dismissed federal bankruptcy proceeding is entitled to preclusive effect. (Id. at 13–18). Setting aside the merits of that argument, it is not an argument that can be properly made to this Court. Rooker-Feldman bars plaintiffs from seeking relief for “injuries caused by state-court judgments rendered before the district court proceedings commenced.” Exxon Mobil Corp., 544 U.S. at 284. Here, Plaintiff's injury is caused by the state court's judgment of eviction and its subsequent writ of possession. Therefore, this Court has no subject matter jurisdiction to consider the merits of Plaintiffs challenge to those proceedings. Plaintiff could have sought relief by other means with the state court case or the appropriate state appellate court, but it has apparently failed to take advantage of those opportunities. Accordingly, Plaintiffs Emergency Motion for an Injunction Pending Appeal under Rule 62(d) is denied, as Plaintiff failed to demonstrate strong likelihood of success on the merits.
II. Defendant Radhe Krishna Properties, LLC's Motion for Sanctions
Nevertheless, “[t]he district court has authority to proceed forward with portions of the case not related to the claims on appeal.” Johnson v. 3M Co., 55
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F. 4th 1304, 1309 (11th Cir. 2022) (citation omitted). Defendant Radhe Krishna Properties, LLC moves for sanctions against Plaintiff Jaffan International, LLC under Federal Rule of Civil Procedure 11. (Doc. 31). A district court may award Rule 11 sanctions:
(1) when a party files a pleading that has no reasonable factual basis; (2) when the party files a pleading that is based on a legal theory that has no reasonable chance of success and that cannot be advanced as a reasonable argument to change existing law; or (3) when the party files a pleading in bad faith for an improper purpose.
Anderson v. Smithfield Foods, Inc., 353 F. 3d 912, 915 (11th Cir. 2003) (citation omitted). The inquiry under Rule 11 is "whether the party's claims are objectively frivolous" and "whether the person who signed the pleadings should have been aware that they were frivolous.” Baker v. Alderman, 158 F. 3d 516, 524 (11th Cir. 1998) (citation omitted). “Although the timing of sanctions rests in the district judge's discretion, Rule 11 sanctions ‘normally will be determined at the end of litigation." Id. at 523 (quoting Donaldson v. Clark, 819 F. 2d 1551, 1555 (11th Cir. 1987). As Plaintiffs case is currently on appeal, the Court declines to make a determination on the motion for sanctions at this time.
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Accordingly, it is ORDERED that:
1. Plaintiff Jaffan International, LLC's Emergency Motion for an Injunction Pending Appeal under Rule 62(d) (Doc. 28) is DENIED.
2. Defendant Radhe Krishna Properties, LLC's Motion for Sanctions against Plaintiff (Doc. 31) is DENIED without prejudice, and Defendant may refile the motion at a later date.
ORDERED in Tampa, Florida, on December 1, 2025.
/s/ John L. Badalamenti
JOHN L. BADALAMENTI
UNITED STATES DISTRICT JUDGE
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Authorities Cited
- Griggs v. Provident Consumer Disc. Co., 459 U.S. 56 (U.S. 1982)
- Jurldine A. Donaldson v. Clark, 819 F.2d 1551 (11th Cir. 1987)
- Hilton v. Braunskill, 481 U.S. 770 (U.S. 1987)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005)
- Nken v. Holder, 556 U.S. 418 (U.S. 2009)
- Rebekka Anne Behr v. Campbell, 8 F.4th 1206 (11th Cir. 2021)
- Baker v. Alderman, 158 F.3d 516 (11th Cir. 1998)
- Anderson v. Smithfield Foods, Inc., 353 F.3d 912 (11th Cir. 2003)
- MAY v. Morgan Cnty. Ga., 878 F.3d 1001 (11th Cir. 2017)