Milhaven v. Country Village Apartment

Background

Patricia Milhaven alleged that she is a 60-year-old disabled person with multiple sclerosis and lives in housing operated by Country Village Apartment, doing business as Creekside Apartments. She lives with a service dog. According to the complaint, Country Village issued notices restricting Milhaven and her dog because of complaints about the dog, required her to hold the leash in a way she said her disability made impossible, and refused to renew her lease in September 2018.

Country Village later brought eviction proceedings in the Town of Warwick. A local court issued a March 2019 judgment allowing Milhaven’s eviction and requiring her to pay more than $1,350 in rent. The New York Appellate Term later reversed that judgment and sent the matter back for trial. Milhaven’s federal complaint sought an order preventing eviction, renewal of her lease, protection from disability-based harassment, damages, and attorneys’ fees and costs.

Defendant’s arguments

Country Village moved to dismiss under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). It initially relied on the Rooker-Feldman doctrine, which generally prevents a federal trial court from reviewing a state-court judgment, res judicata, which can prevent relitigation of claims resolved by a final judgment, and the law-of-the-case doctrine. After the state-court judgment was reversed, Country Village also argued that the federal court should refrain from deciding the case under Younger abstention and that the Anti-Injunction Act barred the requested relief.

The court agreed that res judicata no longer applied because the state-court judgment had been reversed. It also concluded that the reversal and ongoing state proceedings created a problem under Rooker-Feldman, but allowed Milhaven to amend her complaint rather than dismissing the entire case on that basis.

Younger abstention

Younger abstention is a principle under which federal courts generally refrain from interfering with certain ongoing state proceedings. The court ruled that it did not apply here. The state case was a private landlord-tenant eviction proceeding, not a criminal prosecution, a civil enforcement proceeding, or a civil proceeding involving orders uniquely connected to the state court’s ability to perform its judicial functions.

Anti-Injunction Act

The Anti-Injunction Act generally bars federal courts from issuing injunctions that stop state-court proceedings, subject to three narrow exceptions. The court held that the Act barred Milhaven’s requests to permanently prevent the eviction and to require renewal of her lease because those forms of relief would interfere with the ongoing state eviction proceeding. None of the Act’s exceptions applied.

The court distinguished that barred relief from Milhaven’s other requested remedies. Claims for compensatory and punitive damages, attorneys’ fees and costs, and prospective relief concerning future disability-based harassment unrelated to the state proceeding could continue. The Anti-Injunction Act did not bar those claims.

Disposition

Judge Kenneth M. Karas granted in part and denied in part Country Village’s motion to dismiss. The portions of the complaint seeking to enjoin the ongoing state-court proceedings were dismissed without prejudice under the Anti-Injunction Act. The court granted Milhaven leave to file an amended complaint within 30 days concerning monetary damages and prospective injunctive relief unrelated to the state proceedings, so that she could address the Rooker-Feldman issue. The court warned that failure to amend properly and on time could result in dismissal of the action. The opinion did not decide whether Country Village actually violated the Fair Housing Act.