Murray v. United States Attorney's Office

District Court, W.D. Washington·Decided March 11, 2025·No. 2:25-cv-00259·Unknown

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 SARA MURRAY, CASE NO. 2:25-cv-00259-LK 11 Plaintiff, ORDER DISMISSING COMPLAINT AND DENYING 12 v. PENDING MOTIONS 13 UNITED STATES ATTORNEY’S OFFICE, et al., 14 Defendants. 15 This matter comes before the Court on pro se Plaintiff Sara Murray’s Emergency Motion 16 for Reconsideration, Dkt. No. 11, and Motion for ADA Accommodations, Appointment of 17 Counsel. Dkt. No. 9. The Court also reviews Ms. Murray’s complaint under 28 U.S.C. 18 § 1915(e)(2)(B). For the reasons described below, the Court denies both motions and dismisses 19 the complaint with leave to amend. 20 21 I. BACKGROUND Ms. Murray filed this action on February 7, 2025. Dkt. No. 1. On February 18, Judge 22 Tsuchida granted her motion to proceed in forma pauperis (“IFP”) and in doing so, recommended 23 24 1 that the Court review her complaint under 28 U.S.C. § 1915(e)(2)(B) before issuing summons. 2 Dkt. No. 7. 3 Ms. Murray alleges that the United States Attorney’s Office for the Western District of 4 Washington refused to investigate her criminal complaint regarding an ongoing RICO scheme,

5 thereby obstructing justice and violating her due process rights, and that “[t]heir refusal was based 6 on disability and gender discrimination.” Dkt. No. 8 at 4. She also alleges that the United States 7 Attorney’s Office failed to reasonably accommodate her disability by not providing “an expert 8 investigator with psychological and trauma expertise to take her statement[.]” Id. at 8. Based on 9 these facts, Ms. Murray “brings claims under Title II and Title V of the ADA, Section 504 of the 10 Rehabilitation Act, the Equal Protection and Due Process Clauses of the Fifth Amendment, and 11 federal obstruction of justice statutes.” Id. at 4. She also brings a claim for negligent infliction of 12 emotional distress. Id. at 11. 13 Along with her complaint, Ms. Murray filed two motions. One is a motion for a temporary 14 restraining order and preliminary injunction. Dkt. No. 4. The second motion seeks

15 accommodations under the Americans with Disabilities Act (“ADA”) and court-appointed 16 counsel. Dkt. No. 9. The Court denied Ms. Murray’s motion for a temporary restraining order, 17 finding that it did not qualify for emergency treatment under Federal Rule of Civil Procedure 65(b) 18 and that Ms. Murray failed to follow the procedural requirements outlined in Local Civil Rule 65. 19 Dkt. No. 5. 20 Following that, Ms. Murray moved on an emergency basis for reconsideration. Dkt. No. 21 11. She seeks reconsideration of the Court’s order denying her motion for a temporary restraining 22 order. Id. at 1–2. She also seeks reconsideration of the Court’s “failure to address her motion for 23 ADA accommodations.” Id.

24 1 2 II. DISCUSSION 3 A. Ms. Murray’s Motion for Reconsideration is Denied 4 “Motions for reconsideration are disfavored,” and the Court “will ordinarily deny such

5 motions in the absence of a showing of manifest error in the prior ruling or a showing of new facts 6 or legal authority which could not have been brought to its attention earlier with reasonable 7 diligence.” LCR 12(h)(1). A movant who seeks reconsideration “shall point out with specificity 8 the matters which the movant believes were overlooked or misapprehended by the court, any new 9 matters being brought to the court’s attention for the first time, and the particular modifications 10 being sought in the court’s prior ruling.” LCR 12(h)(2). 11 1. Ms. Murray’s Motion for a Temporary Restraining Order 12 The Court denied Ms. Murray’s motion for a temporary restraining order because it did not 13 qualify for emergency treatment under Federal Rule of Civil Procedure 65(b) or meet the 14 procedural requirements in Local Civil Rule 65. Dkt. No. 5.

15 Ms. Murray argues that the Court made a mistake by denying her motion for a temporary 16 restraining order based in part on her failure to comply with Local Civil Rule 65’s requirement 17 that the motion include a certificate of service and contact information for the opposing party’s 18 counsel. Dkt. No. 11 at 4–5; see also Dkt. No. 5. Ms. Murray notes that she has not been permitted 19 to serve Defendants as summons have not issued, and so Defendants have not entered an 20 appearance in this case. Dkt. No. 11 at 4–5. She argues the Court should not deny her motion based 21 on a procedural requirement that she cannot currently comply with. Id. 22 The Court does not find that persuasive. As described below, Ms. Murray’s motion did not 23 qualify for emergency treatment under Federal Rule of Civil Procedure 65, which is necessary for

24 the Court to issue a temporary restraining order without notice to an adverse party. Because it 1 failed to qualify for emergency treatment, Ms. Murray had to follow Local Civil Rule 65’s 2 procedural requirements for providing notice of the motion to an adverse party, and it was not 3 “legally impossible” for her to do so. Dkt. No. 11 at 5. 4 (a) Ms. Murray’s motion did not meet the requirements for issuing a temporary restraining order without notice to the adverse party 5 “Motions for temporary restraining orders without notice to and an opportunity to be heard 6 by the adverse party are disfavored and will rarely be granted.” LCR 65(b)(1). The Court may 7 issue a temporary restraining order without notice to the adverse party only if two conditions are 8 met: (1) “specific facts in an affidavit or a verified complaint clearly show that immediate and 9 irreparable injury, loss, or damage will result to the movant before the adverse party can be heard 10 in opposition,” and (2) the movant “certifies in writing any efforts made to give notice and the 11 reasons why it should not be required.” Fed. R. Civ. P. 65(b)(1). Neither of these conditions were 12 met here. The only harm Ms. Murray identified in her motion was that “[e]very day that Plaintiff 13 is denied a criminal investigation, the RICO enterprise continues” and that “ADA violations and 14 denial of due process rights cause immediate and ongoing harm.” Dkt. No. 4 at 3. These vague and 15 conclusory allegations do not come close to clearly showing that she would suffer immediate and 16 irreparable harm if the Court does not act before the U.S. Attorney’s Office can be heard in 17 opposition. And Ms. Murray did not certify in writing what efforts she made to notify the U.S. 18 Attorney’s Office of the motion or why that notice should not be required here. 19 (b) Ms. Murray did not follow Local Civil Rule 65’s requirements 20 “Unless the requirements of Fed. R. Civ. P. 65(b) for issuance without notice are 21 satisfied”—and they were not here—then “the moving party must serve all motion papers on the 22 opposing party before or contemporaneously with the filing of the motion and include a certificate 23 of service with the motion.” LCR 65(b)(1). Ms. Murray did not do that either. And the Court 24 1 disagrees that Ms. Murray could not comply with Local Civil Rule 65’s service requirements 2 because summons have not issued; she could have served the U.S.

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