Unreported / Non-Citable
Background
On December 26, 2025, plaintiffs Tarani-Alike Johnson and her co-plaintiff filed a sprawling pro se complaint in the Northern District of California broadly attacking a 2018 Pennsylvania state-court foreclosure verdict against their family home. They asserted twenty-six causes of action — including fraud, conspiracy, RICO, perjury, and due process violations — against Wells Fargo, the law firms and judges involved in the foreclosure, and individuals connected to the underlying loan documentation. They sought a temporary restraining order to block a January 6, 2026 sheriff’s sale.
This was not their first attempt. Plaintiffs had filed several similar suits in the Eastern District of Pennsylvania, six related bankruptcy cases, and other proceedings. Plaintiff Tarani Johnson had been declared a vexatious litigant in the Eastern District of Pennsylvania and enjoined from filing further actions naming Wells Fargo and arising from the foreclosure. Plaintiffs candidly told the court they filed in California to escape that vexatious-litigant order.
Their TRO motion leaned heavily on a February 2025 Pennsylvania Court of Common Pleas order stating that the original 2018 foreclosure verdict had not been reduced to a judgment and that enforcement proceedings were therefore void. They also argued the lien had expired in 2023, that the verdict was the product of fraud on the court (alleging that Wells Fargo officer Veronica Garcia was a “robo-signer”), and that the federal courts had exclusive jurisdiction under 12 U.S.C. § 632.
The Court’s Holding
Judge Haywood S. Gilliam, Jr. denied the TRO. Applying the Winter v. Natural Resources Defense Council standard, the court held that plaintiffs had not shown even “serious questions” going to the merits.
The Rooker-Feldman doctrine likely deprives the court of subject-matter jurisdiction. The doctrine, as articulated by the Ninth Circuit in Doe v. Mann and Noel v. Hall, bars federal district courts from sitting as appellate reviewers of state-court judgments. Plaintiffs’ requested relief — declaring the state foreclosure verdict and writ of execution void and enjoining a sheriff’s sale ordered under that judgment — is the exact relief Rooker-Feldman bars, as the Northern District has repeatedly recognized in Tagoia v. Wells Fargo, Sweeney v. Carringer, and similar cases.
Plaintiffs’ contention that the February 2025 Pennsylvania order had eliminated the judgment was rebutted by the public docket: judgment was entered on April 2, 2025, and Judge Roberts of the Court of Common Pleas of Philadelphia County rejected plaintiffs’ challenges to that judgment and to the writ of execution on December 11, 2025. The federal court could not relitigate either ruling.
The Kougasian v. TMSL, Inc. extrinsic-fraud exception to Rooker-Feldman did not save the motion. Plaintiffs alleged in conclusory terms that Veronica Garcia was a “robo-signer,” but they did not explain what was actually false in her verification, why personal knowledge would have required her presence at the original transaction, or why the alleged fraud would warrant the requested relief. The 12 U.S.C. § 632 argument failed because that statute’s exclusive jurisdiction is limited to actions arising out of property held for foreign states or central banks — not Wells Fargo home foreclosures.
Because plaintiffs failed at the threshold likelihood-of-success element, the court did not reach the other Winter factors. In a footnote, the court warned plaintiffs about apparently fabricated case citations in their motion (citing Brownell v. Bank of America and Friedman v. Bank of America at specific reporter pages that the court could not locate), reminding them of their duty to verify representations and warning of possible sanctions or order to show cause for further inaccuracies.
Key Takeaways
- The Rooker-Feldman doctrine continues to do heavy lifting against pro se federal-court attempts to halt state-court foreclosure sales. Northern District judges treat such TRO motions as de facto appeals of the underlying state judgment.
- The Kougasian extrinsic-fraud exception is real but narrow. Conclusory robo-signer allegations, without specifics about what was false and how the fraud was extrinsic, will not unlock federal jurisdiction.
- Filing in a federal court outside the venue of an existing vexatious-litigant injunction does not give plaintiffs a clean slate. Courts can and do consider that history when evaluating the likelihood of success on the merits.
- 12 U.S.C. § 632 confers exclusive federal jurisdiction only over actions involving property of foreign states or central banks. It is not a general gateway to federal court for suits against national banks.
- Northern District judges are increasingly issuing on-the-record warnings about apparently fabricated or AI-generated case citations and signaling that sanctions may follow.
Why It Matters
Pro se TRO motions to halt sheriff’s sales are a recurring fixture of the Northern District’s emergency docket, especially around year-end when sales are scheduled. This opinion is a clean recent application of the Rooker-Feldman framework to that pattern, and it underscores that even highly sympathetic facts — a family losing its home — cannot overcome the jurisdictional bar against federal review of state-court foreclosure judgments.
The opinion also reflects the federal judiciary’s growing concern about citation accuracy in pro se filings. The court’s footnote warning about cases it could not find — a hallmark of AI-generated brief writing — combined with its candor about plaintiffs’ admitted forum-shopping is a signal that the Northern District is paying close attention to both vexatious litigant patterns and AI-assisted misuse of legal citations.