Woodmont Ramapo LLC v. Parks
- Philip Halpern
- 7:25-cv-07533
- U.S. District Court · Southern District of New York
- 4
Woodmont Ramapo v. Parks: Judge Halpern remanded Parks’s removed state-court case because Parks did not show federal jurisdiction.
Anthony Parks’s removed state-court case was returned to the Ramapo Justice Court, and the federal action was closed. The underlying landlord-tenant dispute was not decided by the federal court.
What happened
In Woodmont Ramapo LLC v. Anthony Parks, Anthony Parks removed a Justice Court case involving past-due rent to federal court. He said the state court’s refusal to let him subpoena witnesses violated his Fourteenth Amendment rights.
The court explained that a state case can be removed only if a federal court could have heard it originally. A federal defense or complaint about how the state court handled the case does not by itself create federal jurisdiction. Parks also did not provide all the state-court papers required for removal.
Judge Philip M. Halpern ruled that Parks had not shown that removal was proper. The court remanded the case to the Ramapo Justice Court, directed the Clerk to close the federal case, and terminated all pending matters.
The detailed version
- Woodmont Ramapo LLC v. Parks · No. 7:25-cv-07533
- Philip Halpern
- Sept. 17, 2025
Background
Anthony Parks, proceeding without a lawyer, filed a notice removing a civil action from the Justice Court of the Town of Ramapo, County of Rockland, to the U.S. District Court for the Southern District of New York. The notice described the state-court matter as a landlord-tenant case. Parks asserted that the state court was not allowing him to subpoena witnesses for a scheduled trial and that this violated his rights under the Fourteenth Amendment.
The notice included several documents, including communications involving Woodmont and a notice from the Ramapo Justice Court about a September 11, 2025 court session. Parks did not state a basis for the federal court’s subject-matter jurisdiction, meaning its legal authority to hear the case. He also did not attach all process, pleadings, and orders served in the state-court proceeding.
Court’s analysis
Federal law permits removal only when the state-court action could originally have been filed in federal court. The party seeking removal has the burden of showing that federal jurisdiction exists. Federal-question jurisdiction generally requires that the plaintiff’s own properly pleaded claim arise under the Constitution, federal laws, or treaties.
The court noted that Parks’s description of the action indicated that it concerned past-due rent. His asserted federal claim—that the Ramapo Justice Court was violating his Fourteenth Amendment rights—was not a claim made in the state-court action itself. Instead, it was an assertion concerning the state court’s handling of the case. The court explained that a federal defense or federal issue raised by a defendant does not ordinarily make a state-court action removable.
The court also found the notice procedurally deficient because Parks had not attached the required state-court pleadings and other papers. Because Parks failed to establish the grounds for federal jurisdiction and the procedural requirements for removal, the court held that removal was improper.
Ruling and effect
The court remanded the action to the Ramapo Justice Court. It directed the Clerk to send a copy of the order to that court and to close the federal action. The court also terminated all pending matters. The opinion does not state that the federal court decided the underlying past-due-rent dispute or Parks’s asserted constitutional issue on the merits.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.