Opinion
Case No. C2-09-454.
June 10, 2009
ORDER
On June 8, 2009, Plaintiff, Dale E. Prey, filed a Complaint in this Court seeking, among other relief, an injunction preventing a court in the State of Arizona, and several court officials, from proceeding with a hearing in the matter of a traffic citation. The Anti-Injunction Act, however, codified at 28 U.S.C. § 2283, prohibits a federal court from issuing injunctions "to stay proceedings in a State court except as expressly authorized by Act of Congress, or where necessary in aid of its jurisdiction, or to protect or effectuate its judgments." It is now settled that 28 U.S.C.A. § 2283 is "an absolute prohibition against enjoining state court proceedings, unless the injunction falls within one of three specifically defined exceptions." Atlantic Coast Line R.R. Co. v. Bhd. of Locomotive Eng'rs, 398 U.S. 281, 286-87 (1970). The three exceptions to the general prohibition are limited to instances in which Congress has expressly authorized an injunction; where an injunction is necessary in aid of the court's jurisdiction; or where an injunction is necessary to protect or effectuate the court's judgments. Martingale LLC v. City of Louisville, 361 F.3d 297, 302 (6th Cir. 2004); see 28 U.S.C. § 2283. None of these exceptions against the absolute prohibition against the issuance of an injunction applies here.
The statute is designed to prevent conflict between federal and state courts. This policy is particularly compelling in this case in which the litigation of a private party with respect to a traffic violation in the State of Arizona threatens to draw two judicial systems into conflict. For these reasons, to the extent Plaintiff seeks an injunction preventing any hearing, trial, publishing of any order, or any other legal process by the State of Arizona or any of its officials, that request for relief is DENIED.
The Court also notes that it would generally lack jurisdiction to review any judgment against the Plaintiff entered by the State of Arizona with respect to the traffic violation, once the state court disposes of the citation. See Dist. of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983) and Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923).