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 emergency motion to stay state housing proceedings under the Anti-Injunction Act.
Luis Ricardo Munroe’s state-court housing proceeding was not stayed by this order; New York University and the other defendants were not subjected to the requested stay.
What happened
In Munroe v. New York University, Luis Ricardo Munroe asked the federal court to temporarily stop his ongoing state-court housing proceeding. He argued that he would suffer serious harm, was likely to succeed on his federal claims, and that the balance of harms and public interest supported a stay.
The court explained that the Anti-Injunction Act generally prevents federal courts from stopping state-court proceedings. It recognized three narrow exceptions, but found that Munroe’s arguments did not fit any of them. The court also noted that courts in the Southern District of New York have applied the Act to state eviction proceedings.
Judge Sarah Netburn denied Munroe’s emergency motion for a stay. The clerk was directed to terminate the motion, and the court encouraged Munroe to contact the City Bar Justice Center’s legal assistance projects.
The detailed version
- Munroe v. New York University · No. 1:25-cv-03431
- Sarah Netburn
- May 22, 2025
Background
On May 12, 2025, the court had denied Luis Ricardo Munroe’s request to stop or pause his state-court housing proceeding. The court previously explained that the Anti-Injunction Act, 28 U.S.C. § 2283, generally bars a federal court from issuing an injunction that stays a state-court proceeding.
On May 19, 2025, docketed on May 21, 2025, Munroe filed an emergency motion seeking a temporary stay or preliminary injunction. He argued that he would suffer irreparable harm, would succeed on his federal claims, that the defendants would suffer less harm than he would, and that the public interest favored enforcing civil rights and protecting disabled veterans.
Court’s Analysis
The court again applied the Anti-Injunction Act. The Act has three limited exceptions: another act of Congress must expressly authorize the order; the order must be necessary to aid the federal court’s jurisdiction; or the order must be needed to protect or enforce the federal court’s judgments. The court found that Munroe’s arguments did not fall within any of these exceptions.
The court also cited decisions holding that the Anti-Injunction Act prevents federal courts from stopping ongoing state eviction proceedings, whether the request is made through a temporary restraining order or a preliminary injunction. The court did not decide the merits of Munroe’s underlying federal claims.
Disposition
Judge Sarah Netburn denied Munroe’s emergency motion for a stay. The clerk was directed to terminate the motion at ECF No. 14. The court 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 housing-stability or veterans-assistance projects.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.