Brown v. RXR Soyo Exalta, LLC

Background

Marla Brown proceeded without a lawyer and invoked federal-question jurisdiction. She alleged that RXR Soyo Exalta, LLC (Sawyer Place), which appears to be her landlord, was violating her “civil/sovereign” rights in connection with eviction proceedings in Yonkers City Court.

Brown alleged that she entered into a “trust deed” with the defendant concerning an apartment unit, sent notices and a “Bonded Bill of Exchange,” and asserted that the defendant failed to respond. She alleged that the defendant later filed a nonpayment case in Yonkers City Court. Brown’s complaint asserted claims including breach of fiduciary duty, wrongful termination of her beneficial interest in the property, and a request for an accounting. She also sought a declaration concerning her right to remain in the apartment without threatened eviction.

Brown filed an emergency motion asking the federal court to stay the Yonkers City Court judgment entered on April 18, 2024. She attached a May 22, 2024 notice directing her to leave the apartment by June 7, 2024.

Court’s analysis

A preliminary injunction is an extraordinary form of emergency relief. To obtain one, a party must show likely irreparable harm and either a likelihood of success on the merits or sufficiently serious questions for litigation together with a balance of hardships that strongly favors the party seeking relief.

The court concluded that Brown’s complaint and motion did not show a likelihood of success or sufficiently serious questions supporting an injunction. The court also stated that the filings did not allege facts showing that the federal court had subject-matter jurisdiction, meaning legal authority to hear the claims.

The court further explained that, depending on whether the state eviction proceedings were ongoing or final, federal intervention was likely barred by either the Younger abstention doctrine or the Rooker-Feldman doctrine. Younger generally limits federal-court interference with ongoing state proceedings. Rooker-Feldman generally prevents federal district courts from reviewing final state-court judgments.

Ruling

The court denied Brown’s request for preliminary injunctive relief and denied her request for an order to show cause. It stated that it would address the claims in her complaint in due course, so this order did not resolve those claims. The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal from the order would not be taken in good faith and denied permission to appeal without paying filing fees.

Classification

This is a procedural order because the court denied emergency relief based on the requirements for a preliminary injunction and possible jurisdictional and state-court-interference barriers, without deciding the underlying claims.