Munroe v. New York University
- Sarah Netburn
- 1:25-cv-03431
- U.S. District Court · Southern District of New York
- 2
In Munroe v. New York University, Judge Netburn denied Munroe’s request to stop his state housing eviction proceedings under federal law.
Luis Ricardo Munroe and the ongoing state-court housing proceeding involving New York University.
What happened
In Munroe v. New York University, Luis Ricardo Munroe asked the federal court to intervene before New York University’s eviction action continued in state housing court. He described the request as involving his federal civil-rights and disability claims.
The court treated Munroe’s letter as a request to stop or pause the state-court eviction proceedings. It explained that federal law generally bars federal courts from stopping state-court proceedings, subject to three narrow exceptions, and that those exceptions did not permit the requested relief here.
United States Magistrate Judge Sarah Netburn denied Munroe’s request to stop or pause the state housing proceeding. The court encouraged him to contact the City Bar Justice Center’s Federal Pro Se Legal Assistance Project for possible assistance or referrals.
The detailed version
- Munroe v. New York University · No. 1:25-cv-03431
- Sarah Netburn
- May 12, 2025
Background
On May 7, 2025, and docketed on May 9, 2025, Luis Ricardo Munroe filed a letter asking the court to intervene in his ongoing state-court housing proceedings. He asked the court to assert jurisdiction over his federal civil-rights and Americans with Disabilities Act claims before the state housing court proceeded with New York University’s eviction action. The court construed the request as seeking an order stopping or pausing the state-court eviction proceedings.
Legal standard
The court applied the Anti-Injunction Act, 28 U.S.C. § 2283. That law generally prohibits a federal court from issuing an injunction—a court order requiring someone to stop an action—to halt proceedings in state court. The statute contains three exceptions: when Congress expressly authorizes the injunction, when it is necessary to protect the federal court’s jurisdiction, or when it is necessary to protect or enforce the federal court’s judgments. The court stated that these exceptions are narrowly interpreted and noted that courts in the district regularly hold that the Act bars federal interference with state eviction proceedings.
Ruling
Judge Sarah Netburn denied Munroe’s request to enjoin or stay his state-court housing proceeding. The opinion did not decide the merits of Munroe’s federal civil-rights or disability claims. The court also encouraged Munroe to contact the City Bar Justice Center’s Federal Pro Se Legal Assistance Project, which could assist him or refer him to other listed projects.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.