Opinion
Civil Action 22-05797-KMW-MJS
12-28-2023
HILDA T. KENNEDY, Plaintiff, v. THE NEW JERSEY COURT SYSTEM, et al., Defendants.
MEMORANDUM ORDER
HONORABLE KAREN M. WILLIAMS, DISTRICT JUDGE.
1. The Court has received and reviewed Plaintiffs request to stay her state court proceedings (ECF No. 32).
2. Plaintiff requests a stay pursuant to the Anti-Injunction Act, 28 U.S.C. § 2283 (“A court of the United States may not grant an injunction to stay proceedings in a State court except as expressly authorized by an Act of Congress, or where necessary in aid of its jurisdiction or effectuate its judgments. ”).
3. In this matter, there is no express Act of Congress applicable, and Plaintiff believes that her case falls within the “necessity in aid” exception.
4. The “necessity in aid” exception has been primarily found in circumstances relating to land and property, see Sid. Microsystems Corp. v. Tex. Instruments, Inc., 916 F.2d 58, 60 (2d Cir. 1990) (collecting cases), and also to complex matters such as a class action. In re Asbestos Sch. Litig., No. 83-0268, 1991 WL 61156 at *2 (E.D, Pa, Apr, 16,1991). Further, the “necessity in aid” exception can be applicable in circumstances “where a federal court has made conclusive rulings and their effect may be undermined by threatened relitigation in state courts,” Std. Microsystems Corp., 916 F.2d at 60. Neither of these circumstances are present in Plaintiffs state action, and in fact, the existence of the state court action does not in any way impair the jurisdiction of the federal court or its ability to render justice related to her federal claims.
5. The exceptions related to the Anti-Injunction Act do not apply to Plaintiffs case.
Thus, it is clear that this Court must not interfere with the state court proceeding and must decline Plaintiffs request for a stay of her state court proceeding.