Myers v. Itasca County HRA

Background

For two years, Tricia Marie Myers used Section 8 housing vouchers from the Itasca County Housing and Redevelopment Authority (HRA). During an October 2023 recertification, the HRA determined that it had overpaid Myers because of backdated increases in her son’s earnings. Myers disagreed with the calculation but agreed to repay part of the benefits to avoid termination of her vouchers.

Myers later reported a fire in her home, its alleged uninhabitability, and an alleged retaliatory eviction by her landlord. The HRA then terminated her vouchers without giving her an opportunity to contest the termination in a formal hearing. Myers sued the HRA and its employees Diane Larson, Carrie Schmitz, and Kenda Roddenberg in their official and individual capacities. She alleged violations of due process and equal protection.

Motions for injunctive relief

Myers asked the court to prohibit the Itasca County District Court and the Minnesota Court of Appeals from moving forward with a criminal prosecution that she alleged was retaliation for this lawsuit and other claims filed against entities in Itasca County. She filed a Motion for Injunction and a Motion for Expedited Review and Injunction.

The court denied both motions for several independent reasons:

- No standing. Standing is the legal requirement that a plaintiff show a concrete injury caused by the defendants and likely to be fixed by the requested order. The court found that Myers’s alleged injury came from the Itasca County District Court, not from the HRA or its employees. Because that court was not a party to the case, the alleged injury was not traceable to the named defendants. - Anti-Injunction Act. The Anti-Injunction Act generally prohibits federal courts from issuing injunctions that stop state-court proceedings, subject to statutory exceptions. The court concluded that the requested relief was prohibited by that law. - Review of state-court decisions. To the extent Myers sought to overturn decisions already issued by state courts, the court stated that the proper route was through the Minnesota appellate courts and ultimately the United States Supreme Court. The court held that the Rooker-Feldman doctrine, which generally prevents lower federal courts from reviewing state-court judgments, also required denial of the motions in that respect.

Disposition

The court ordered that Myers’s Motion for Injunction and Motion for Expedited Review and Injunction were DENIED. The opinion addressed only the requested injunctions; it did not decide the merits of Myers’s underlying due-process and equal-protection claims against the HRA and its employees.