Williams v. Navarro
- Proceeding
- district
- Area
- civil
- On appeal
- Lance Williams v. Navarro (2024-04-30) — affirmed — the Ninth Circuit's later ruling on this docket
- Panel
- Todd W. Robinson (author)
Analysis
The court considered Plaintiff's objections to a Magistrate Judge's Report and Recommendation recommending summary judgment for Defendants, which had already been adopted by the District Court. The court determined it lacked jurisdiction to rule on the objections because the Plaintiff had filed a notice of appeal, and therefore issued an indicative ruling stating it would have considered the objections if it had jurisdiction.
| What the court decided | The model |
|---|---|
Declined to rule on Plaintiff's objections to the Report and Recommendation due to lack of jurisdiction.“If the Court had jurisdiction, it would consider and rule on Plaintiff's objections.” | agree with court The court correctly identified that the filing of a notice of appeal divests the district court of jurisdiction over the case. Because the court had already adopted the R&R and closed the case, and the Plaintiff subsequently appealed, the district court could no longer enter a final order on the merits of the objections. The 'indicative ruling' is a procedural mechanism to preserve the record for the appellate court, showing what the district court would have done had it retained jurisdiction. This follows standard federal appellate procedure. |
The order itself: sound — The order is procedurally sound. It correctly applies the jurisdictional bar created by the notice of appeal. It cites the appropriate Ninth Circuit authority for the proposition that jurisdiction is divested (Stein) and for the practice of issuing indicative rulings in this context (Mendia). The reasoning is concise and directly addresses the procedural posture.
Opinion
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 LANCE WILLIAMS, Case No.: 18-CV-1581 TWR (KSC)
12 Plaintiff, INDICATIVE RULING 13 v. (ECF No. 175) 14 OFFICER NAVARRO, et al., 15 Defendant. 16 17 18 Presently before the Court are Plaintiff’s objections (ECF No. 175, “Obj.”) to 19 Magistrate Judge Karen S. Crawford’s Report and Recommendation re Defendants’ 20 Motion for Summary Judgment (ECF No. 172, “R&R”) recommending that the Court grant 21 Defendant’s Motion. The Court adopted the Report and Recommendation on September 22 30, 2022, prior to receiving Plaintiff’s objections, and closed the case. (ECF No. 173.) 23 Plaintiff had timely mailed his objections to the Report and Recommendation, but they did 24 not reach the Court before the filing deadline. (See generally “Obj.”) Before the Court 25 had an opportunity to review and rule on Plaintiff’s objections, Plaintiff filed a notice of 26 appeal (ECF No. 176) divesting this Court of jurisdiction. See Stein v. Wood, 127 F.3d 27 / / / 28 / / / 1 |] 1187, 1189 (th Cir. 1997). If the Court had jurisdiction, it would consider and rule on 2 || Plaintiff's objections. See Mendia v. Garcia, 874 F.3d 1118, 1121-22 (9th Cir. 2017). 3 4 Dated: October 20, 2022 —— (2 5 dd) D (oe 6 Honorable Todd W. Robinson 5 United States District Judge 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28