Opinion
2:23-CV-920-NR
07-18-2023
NAN SHI, Plaintiff, v. MEYERS MANAGEMENT CO., INC., Defendant.
ORDER
J. Nicholas Ranjan United States District Judge
Before the Court is Plaintiff Nan Shi's motion for preliminary injunction (ECF 18), and his accompanying motion for a hearing in support of that request for an injunction (ECF 27). After carefully considering the parties' arguments and the relevant law, the Court concludes that it lacks jurisdiction to issue an injunction in this case.
Under the Anti-Injunction Act, a federal district court “may not grant an injunction 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.” 28 U.S.C. § 2283. None of those narrow exceptions apply here.
First, no laws passed by Congress exempt this type of proceeding.
Second, no previous judgment from this Court is “at risk.”
Third, an injunction is not necessary to aid the Court's jurisdiction. This exception typically applies where “a plaintiff cannot present his or her federal claims in the state court eviction proceeding.” Frankel v. Guzman, No. 20-5208, 2020 WL 6161512, at *2 (E.D. Pa. Oct. 21, 2020) (citation omitted)). The exception does not apply here because there are no federal claims to present (either in this case or in the state-court eviction proceedings). So the requested injunction will not “aid” this Court's exercise of federal jurisdiction.
Therefore, the Court finds that the Anti-Injunction Act prevents exercising jurisdiction in this case, and so Mr. Shi's motion must be DENIED. Frankel, 2020 WL 6161512, at *2 (collecting cases). His motion for a hearing is also DENIED as moot.