UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAKE CHARLES DIVISION

BUBBA JONATHAN WHITMAN CASE NO. 2:25-CV-01577

VERSUS JUDGE JAMES D. CAIN, JR.

TONY LAMBRIGHT ET AL MAGISTRATE JUDGE LEBLANC

MEMORANDUM ORDER Before the court is a second Motion for Preliminary Injunction and Motion for Temporary Restraining Order [doc. 12] filed by pro se plaintiff Bubba Jonathan Whitman, following the amendment of his complaint. See doc. 11. Plaintiff raises claims against several Vernon Parish officials under

and the Declaratory Judgment Act, alleging that his constitutional rights were violated when the district court for that parish registered and other officials enforced a Tennessee child support order that plaintiff maintains is invalid.

To be entitled to a preliminary injunction, applicants must show “1) a substantial likelihood that they will prevail on the merits, (2) a substantial threat that they will suffer irreparable injury if the injunction is not granted, (3) their substantial injury outweighs the threatened harm to the party whom they seek to enjoin, and (4) granting the preliminary injunction will not disserve the public interest.” City of El Cenizo, Tex. v. Texas,

(5th Cir. 2018) (internal quotations omitted). TROs and preliminary injunctions are considered under the same standard. E.g., Thompson v. Penny,

, at *3 n. 27 (E.D. La. June 27, 2025). In denying plaintiff’s prior request for injunctive relief, the court noted that the complained-of Louisiana state court ruling from 2023 was presumably final with appeal

deadlines either having lapsed or any appeal being denied. Whitman v. Lambright,

, at *1 (W.D. La. Oct. 24, 2025). Plaintiff’s direct and indirect challenges to that ruling thus implicated the Rooker-Feldman doctrine, which divests federal district courts of jurisdiction “to entertain collateral attacks on state court judgments.” Kam v. Dallas Cnty.,

, 455 (5th Cir. 2019) (quoting Liedtke v. State Bar of Tex.,

(5th Cir. 1994)); see also Exxon Mobil Corp. v. Saudi Basic Indus.,

(2005) (Rooker-Feldman applies to “cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the federal district court proceedings commenced and inviting district court review and rejection of those judgments.”) Further noting that Rooker-Feldman was frequently used by federal courts to avoid review of state court family law matters, the undersigned denied plaintiff’s motions

because he could not show a likelihood of success on the merits. Whitman,

at *1–*2 (citing Roland v. Texas,

, at *7 (E.D. Tex. Jan. 26, 2022)). Plaintiff now attempts to plead around Rooker-Feldman, arguing that he is not seeking review of a state court judgment but attempting “to halt ongoing constitutional

violations by state officials[.]” Doc. 11, ¶ 14. He also asserts, in reliance on Miller v. Dunn,

(5th Cir. 2022), that Rooker-Feldman does not apply “to the extent registration/enforcement and related collateral issues remain active[.]”

But Miller holds only that Rooker-Feldman does not apply when the appeal is still pending.

. Additionally, all of plaintiff’s claims stem from the fact that he believes the state court erred in registering the child support order—a matter for state court review. Accord Collins v. Garcia,

, at *6 (N.D. Tex. May 12, 2020) (“Even though Plaintiff attempts to classify his claims as seeking relief from civil rights violations, the sole cause of his alleged injury is the adverse judgment itself”) Finally, plaintiff alleges that he did not appeal the state district court’s order because he was denied IFP status. Doc. 11, § 18. To the extent that plaintiff would raise this as a separate claim, he also fails to show a likelihood of success on the merits.! Accordingly, there is still no basis for granting the requested injunctive relief and the Motions [doc. 12] are hereby DENIED. THUS DONE AND SIGNED in Chambers on the 29th day of October, 2025.

UNITED STATES DISTRICT JUDGE

' Although plaintiff has received IFP status in this matter, based on a claim of no income, he does not attach any documents showing what was presented to the state courts or what his income and assets were at the time of those applications.

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