{"id":363,"date":"2026-01-05T12:00:00","date_gmt":"2026-01-05T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=363"},"modified":"2026-01-05T12:00:00","modified_gmt":"2026-01-05T12:00:00","slug":"johnson-wells-fargo-rooker-feldman-tro-foreclosure","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=363","title":{"rendered":"Johnson v. Wells Fargo \u2014 N.D. Cal. denies TRO blocking Pennsylvania foreclosure sale on Rooker-Feldman grounds"},"content":{"rendered":"
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Case<\/dt>\n
Tarani-Alike Johnson, et al. v. Wells Fargo Bank N.A., et al.<\/dd>\n
Court<\/dt>\n
U.S. District Court \u2014 Northern District of California<\/dd>\n
Date Decided<\/dt>\n
2026-01-05<\/dd>\n
Docket No.<\/dt>\n
4:25-cv-10992<\/dd>\n
Status<\/dt>\n
Unreported \/ Non-Citable<\/dd>\n
Topics<\/dt>\n
Temporary restraining order; Rooker-Feldman doctrine; foreclosure; vexatious litigant; Kougasian<\/em> extrinsic fraud exception; 12 U.S.C. \u00a7 632; Winter<\/em> standard; AI-generated case citations<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

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 \u2014 including fraud, conspiracy, RICO, perjury, and due process violations \u2014 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\u2019s sale.<\/p>\n

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.<\/p>\n

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 \u201crobo-signer\u201d), and that the federal courts had exclusive jurisdiction under 12 U.S.C. \u00a7 632.<\/p>\n

The Court’s Holding<\/h2>\n

Judge Haywood S. Gilliam, Jr. denied the TRO. Applying the Winter v. Natural Resources Defense Council<\/em> standard, the court held that plaintiffs had not shown even \u201cserious questions\u201d going to the merits.<\/p>\n

The Rooker-Feldman doctrine likely deprives the court of subject-matter jurisdiction. The doctrine, as articulated by the Ninth Circuit in Doe v. Mann<\/em> and Noel v. Hall<\/em>, bars federal district courts from sitting as appellate reviewers of state-court judgments. Plaintiffs\u2019 requested relief \u2014 declaring the state foreclosure verdict and writ of execution void and enjoining a sheriff\u2019s sale ordered under that judgment \u2014 is the exact relief Rooker-Feldman bars, as the Northern District has repeatedly recognized in Tagoia v. Wells Fargo<\/em>, Sweeney v. Carringer<\/em>, and similar cases.<\/p>\n

Plaintiffs\u2019 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\u2019 challenges to that judgment and to the writ of execution on December 11, 2025. The federal court could not relitigate either ruling.<\/p>\n

The Kougasian v. TMSL, Inc.<\/em> extrinsic-fraud exception to Rooker-Feldman did not save the motion. Plaintiffs alleged in conclusory terms that Veronica Garcia was a \u201crobo-signer,\u201d 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. \u00a7 632 argument failed because that statute\u2019s exclusive jurisdiction is limited to actions arising out of property held for foreign states or central banks \u2014 not Wells Fargo home foreclosures.<\/p>\n

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<\/em> and Friedman v. Bank of America<\/em> 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.<\/p>\n

Key Takeaways<\/h2>\n