Sajady v. Rubio
MasAti Sajady, formerly known as Masood Sajady v. Marco Rubio, in his official capacity as United States Secretary of State; and Robert F. Kennedy, Jr., in his official capacity as United States Secretary of Health and Human Services
- Jerry Blackwell
- 0:26-cv-02967
- U.S. District Court · District of Minnesota
- 2
In Sajady v. Rubio, Judge Blackwell denied plaintiff's renewed request for a temporary restraining order and expedited discovery, citing lack of likely success and serious jurisdictional doubts.
Individuals whose passports have been confiscated under state child support arrearage laws and who seek emergency federal court relief; litigants facing jurisdictional barriers under the Rooker-Feldman doctrine when attempting to bring constitutional claims in federal court arising from state-law proceedings.
What happened
In MasAti Sajady v. Marco Rubio and Robert F. Kennedy, Jr., plaintiff MasAti Sajady (formerly known as Masood Sajady) sued two federal cabinet officials in their official capacities, seeking an emergency court order to address what appears to be the confiscation of his passport. He filed a renewed motion asking the court to immediately halt the harm and also sought to begin gathering evidence quickly through expedited discovery.
The court found that Sajady's passport appears to have been confiscated under Minnesota state law related to unpaid child support. The court raised serious concerns that it may not have the legal authority — jurisdiction — to hear the case at all, citing a legal rule called the Rooker-Feldman doctrine, which generally prevents federal courts from reviewing certain state court judgments. The court also noted that there may be adequate administrative procedures available to Sajady to address his situation, and that he had not shown why normal court procedures were insufficient to protect him from harm.
Judge Jerry W. Blackwell denied both the renewed motion for a temporary restraining order and the motion for expedited discovery. The discovery motion was denied as premature because the defendants had not yet been served with the lawsuit or given a chance to respond. The court emphasized that the jurisdictional questions must be resolved before anything else can move forward.
The detailed version
- Sajady v. Rubio · No. 0:26-cv-02967
- Jerry W. Blackwell
- June 25, 2026
Background
Plaintiff MasAti Sajady, formerly known as Masood Sajady, brought suit against Marco Rubio in his official capacity as United States Secretary of State, and Robert F. Kennedy, Jr., in his official capacity as United States Secretary of Health and Human Services. The opinion does not describe the full allegations of the complaint, but states that Sajady's passport appears to have been confiscated pursuant to Minnesota law related to child support arrearages (past-due child support payments).
Sajady filed a Renewed Motion for Temporary Restraining Order (TRO) and a Motion for Expedited Discovery. This was not the first such request; the court references a prior Order dated June 18, 2026, in which similar relief was denied.
The Motions at Issue
Renewed Motion for Temporary Restraining Order
A temporary restraining order is an emergency court order that can stop certain actions from occurring while a lawsuit proceeds. To obtain one, a party generally must demonstrate, among other things, a likelihood of success on the merits of the underlying claims and that ordinary litigation procedures are inadequate to prevent the alleged harm.
The court denied the renewed TRO for the same reasons given in its June 18, 2026 order and for additional reasons stated in this order:
1. Inadequacy of ordinary procedures not shown. While Sajady identified some upcoming travel — some of which appeared business-related — he did not demonstrate why normal litigation procedures were insufficient to address the alleged harm.
2. Likelihood of success not shown. The court found serious concerns on two fronts: - Jurisdictional concerns: The court cited the Rooker-Feldman doctrine — a legal rule that generally bars federal district courts from reviewing matters that are effectively appeals of state court judgments — and referenced Olson v. Kambiri, No. 13-1777, 2014 WL 2858164 (D. Minn. June 18, 2014), which applied this doctrine to find no jurisdiction in a related context. The court stated these jurisdictional concerns must be addressed first before the merits of any constitutional claim can be reached. - Other potential defenses: The court also referenced Risenhoover v. Wash. Cnty. Cmty. Servs., 545 F. Supp. 2d 885 (D. Minn. 2007), which held that an available administrative complaint procedure provides adequate due process where a county has certified that a person owes more than $2,500.00 in past-due child support. The court suggested this and other defenses may apply to any constitutional claim Sajady is raising.
Motion for Expedited Discovery
Expedited discovery refers to a request to gather evidence from the opposing party earlier and faster than the normal court schedule would allow. The court denied this motion as premature, explaining that the defendants had not yet been served with the lawsuit and had not had an opportunity to respond to the complaint. The court again noted that the jurisdictional concerns must be addressed before discovery could be permitted.
Disposition
The court denied both the Renewed Motion for Temporary Restraining Order and the Motion for Expedited Discovery (both contained in Doc. No. 5).
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.