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S.D.N.Y.Procedural orderFiled Aug. 27, 2025

Aziz v. Butt

Judge
Laura Swain
Docket
7:25-cv-05789
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedurePro Se
In one sentence

In Aziz v. Butt, Judge Clarke denied Javaid Aziz’s motion to vacate state-court judgments because federal district courts cannot review them under Rooker-Feldman.

Who this affects

The ruling directly affects Plaintiff Javaid Aziz’s request to vacate state-court judgments and governs his future motion filings in this case; the opinion does not state that any defendant had been served.

What happened

In Aziz v. Butt, Javaid Aziz, representing himself and acting for Jamila K. Butt under a power of attorney, brought civil-rights and other claims. He also sought emergency court orders, which the court had previously denied.

Aziz then asked the federal court to vacate state-court judgments. The court ruled that the Rooker-Feldman doctrine barred it from reviewing those judgments because Aziz lost in state court, filed this case afterward, claimed injuries caused by the judgments, and asked the federal court to reject them. The court also stated that a rule requiring federal courts to refrain from certain domestic-relations matters would independently apply.

The court denied Aziz’s motion. Judge Jessica G. L. Clarke also warned that continued filing of nearly identical motions could lead to a requirement that he submit a letter before filing future motions, and that later noncompliant motions could be denied outright.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Aziz v. Butt · No. 7:25-cv-05789
Judge
Laura Swain
Date
Aug. 27, 2025

Background

Javaid Aziz, proceeding without a lawyer, filed this action for himself and as attorney-in-fact for Jamila K. Butt. The complaint asserted civil-rights claims under 42 U.S.C. § 1983 and various state and common-law claims. Aziz also filed requests for a preliminary injunction and an emergency temporary restraining order; the court denied those requests on August 5, 2025, and denied a later emergency application for similar reasons.

Aziz then moved to vacate various state-court judgments mentioned in his earlier filings. The opinion states that he had not yet served the summons and complaint on any defendant, but had filed four nearly identical applications for relief.

Court’s reasoning

The court denied the motion because the Rooker-Feldman doctrine barred the requested relief. That doctrine prevents a federal district court from reviewing a state-court judgment when the federal plaintiff lost in state court, alleges injuries caused by that judgment, began the federal case afterward, and asks the federal court to reject or invalidate the state-court ruling. The court found that each requirement was met here. It also stated that the domestic-relations abstention doctrine, which can require a federal court to refrain from deciding certain domestic-relations matters, would independently apply, as the court had previously explained.

Disposition

The court denied Aziz’s motion to vacate the state-court judgments. It also warned that if Aziz continued filing substantively similar motions, the court might require a pre-motion letter before future filings; later motions that did not comply could be denied outright. The order was signed by Jessica G. L. Clarke, United States District Judge.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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