(PS) Anthony v. County of Solano

CourtDistrict Court, E.D. California
DecidedSeptember 5, 2025
Docket2:25-cv-02248
StatusUnknown

This text of (PS) Anthony v. County of Solano ((PS) Anthony v. County of Solano) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
(PS) Anthony v. County of Solano, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 SUSAN BRASHEAR ANTHONHY, No. 2:25-cv-02248-TLN-CKD (PS) 12 Plaintiff, 13 v. FINDINGS AND RECOMMENDATIONS 14 COUNTY OF SOLANO, et al.

15 Defendants. 16 17 Plaintiff, proceeding without counsel, brings this motion for temporary restraining order 18 (ECF No. 4) that is before the undersigned pursuant to Local Rule 302(c)(21). See 28 U.S.C. § 19 636(b)(1). Plaintiff’s motion is appropriate for decision without oral argument within the 20 meaning of Local Rule 230(g). For the reasons set forth below, plaintiff’s motion should be 21 denied and this action dismissed. 22 I. Procedural Background 23 On August 8, 2025, plaintiff Susan Anthony commenced this action by filing a complaint 24 and paying the filing fee. (ECF No. 1.) The named defendants consist of three counties, five 25 magistrate judges, a sheriff’s deputy, and two county attorneys. (Id., ¶¶ 17-22.) Broadly 26 speaking, plaintiff claims defendants engaged in a years-long “campaign of constitutional 27 violations, disability discrimination, and retaliatory prosecution” against her. (Id., ¶ 1.) Her 28 complaint “involves numerous events and facts that happened over several years.” (Id., ¶ 25.) 1 The gravamen of the complaint challenges county law enforcement actions concerning a dog- 2 breeding operation on plaintiff’s property, culminating in her arrest in June 2024, a second arrest 3 in June 2025, and related court proceedings. (See id., ¶¶ 178, 272.) Plaintiff asserts federal 4 claims under the Americans with Disabilities Act (ADA); the Rehabilitation Act; the Racketeer 5 Influenced and Corrupt Organizations (RICO) Act; and 42 U.S.C. § 1983, claiming defendant 6 Solano County violated her due process rights, equal protection rights, and First Amendment 7 rights. She also asserts several state claims. 8 On September 2, 2025, plaintiff filed an unsigned motion for a temporary restraining 9 order. (ECF No. 4.) On September 3, 2025, she filed a document called a “TRO Supplemental” 10 in which she stated that a signature page for the TRO application was attached as Exhibit 1. (ECF 11 No. 5 at 3, 10.) However, there is no attachment to the document consisting of a signature page. 12 See L.R. 131(b) (all pro se pleadings and non-evidentiary documents must be signed by the 13 person appearing on her own behalf). Plaintiff seeks a temporary restraining order staying an 14 August 18, 2025 bench warrant for her arrest, arguing that the warrant is unconstitutional and she 15 is the sole caretaker for her 98-year-old mother. (ECF No. 4 at 7.) Plaintiff also seeks an order 16 “mandating [a] proper probable cause hearing before any detention”; “enjoining warrantless 17 surveillance” of her property; “requiring preservation of all evidence relevant to constitutional 18 claims”; and “providing humanitarian protection for elderly dependent care[.]” (Id. at 1.) 19 II. Legal Standard 20 The purpose of a temporary restraining order under Rule 65(b) of the Federal Rules of 21 Civil Procedure is to preserve the status quo and to prevent irreparable harm “so long as is 22 necessary to hold a hearing, and no longer.” Granny Goose Foods, Inc. v. Bhd. of Teamsters, 415 23 U.S. 423, 439 (1974). In determining whether to issue a temporary restraining order, a court relies 24 on the factors that guide the evaluation of a request for preliminary injunctive relief: whether the 25 moving party is (1) “likely to succeed on the merits,” (2) “likely to suffer irreparable harm in the 26 absence of preliminary relief,” (3) “the balance of equities tips in [its] favor,” and (4) “an 27 injunction is in the public interest.” Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7, 20 28 (2008); see also Stuhlbarg Int’l. Sales Co. v. John D. Brush & Co., 240 F.3d 832, 839 n.7 (9th 1 Cir. 2001) (stating the analysis for temporary restraining orders and preliminary injunctions is 2 “substantially identical”). 3 Courts within this circuit may also consider a request for a temporary restraining order 4 using a “sliding scale” test in which “a stronger showing of one element may offset a weaker 5 showing of another.” Alliance for the Wild Rockies v. Cottrell, 632 F.3d 1127, 1131 (9th Cir. 6 2011). “[W]hen plaintiffs establish that the balance of hardships tips sharply in their favor, there 7 is a likelihood of irreparable injury, and the injunction is in the public interest, they need only 8 show ‘serious questions’ on the merits.” Where Do We Go Berkeley v. California Dep’t of 9 Transp., 32 F.4th 852, 859 (9th Cir. 2022) (citing Alliance for the Wild Rockies, 632 F.3d at 10 1135). 11 However, likelihood of success on the merits is the most important Winter factor, and it is 12 relevant to the court’s evaluation of the other factors. See Baird v. Bonta, 81 F.4th 1036, 1044 13 (9th Cir. 2023). Without showing a likelihood of success on the merits, plaintiff also does not 14 establish that the balance of equities tips in his favor, or that an injunction is in the public interest. 15 See id.; Winter, 555 U.S. at 20-21. 16 The Eastern District of California’s local rules impose specific requirements on those who 17 request a temporary restraining order. See Local Rule 231. Among other things, these rules 18 require “actual notice to the affected party and/or counsel” except in “the most extraordinary of 19 circumstances.” Local Rule 231(a). “Appropriate notice would inform the affected party and/or 20 counsel of the intention to seek a temporary restraining order, the date and time for hearing to be 21 requested . . . , and the nature of the relief to be requested.” Id. 22 A court may issue a temporary restraining order “without written or oral notice to the 23 adverse party” only if 24 (A) specific facts in an affidavit or a verified complaint clearly show that immediate and irreparable injury, loss, or damage will result to 25 the movant before the adverse party can be heard in opposition; and 26 (B) the movant’s attorney certifies in writing any efforts made to give notice and the reasons why it should not be required. 27 28 Fed. R. Civ. P. 65(b)(1). 1 When deciding whether to issue a temporary restraining order, the court may rely on 2 declarations, affidavits, and exhibits, among other things. See Johnson v. Couturier, 572 F.3d 3 1067, 1083 (9th Cir. 2009). This evidence need not conform to the standards that apply at 4 summary judgment or trial. Id.; Flynt Distrib. Co. v. Harvey, 734 F.2d 1389, 1394 (9th Cir. 5 1984). 6 III. Analysis 7 In a similar case in this district, Johnson v. El Dorado Superior Court, No. 2:23-cv-02843- 8 DJC-CKD, 2023 WL 8477982 (E.D. Cal. Dec.

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(PS) Anthony v. County of Solano, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-anthony-v-county-of-solano-caed-2025.