Bradley v. Superior Court of New Haven

CourtDistrict Court, D. Connecticut
DecidedSeptember 12, 2022
Docket3:22-cv-01101
StatusUnknown

This text of Bradley v. Superior Court of New Haven (Bradley v. Superior Court of New Haven) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bradley v. Superior Court of New Haven, (D. Conn. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

ANNE M. BRADLEY, Civil Action No. Plaintiff, 3: 22-CV-1101 (CSH) v. SUPERIOR COURT OF NEW HAVEN In the Matter of Anne M. Bradley, Pro Se V. SEPTEMBER 12, 2022 Storquest Storage Association,

Defendant. RULING ON COMPLAINT - REQUEST FOR INJUNCTION HAIGHT, Senior District Judge: I. BACKGROUND Pro se plaintiff Anne M. Bradley has filed a “Complaint and Request for an Injunction,” requesting that this Court enjoin the Connecticut Superior Court, Judicial District of New Haven, by entering orders to reverse those made by the state court in the pending small claims action of Bradley v. Storquest Self Storage Association, NNH-CV22-5054091-S (Conn. Super. Ct. 2022). On or about July 6, 2022, Plaintiff commenced her state action, seeking to recover $5,000 plus pre- judgment interest due to alleged “fraudulent billing” by defendant Storquest Self Storage Association (“Storquest”) for taxes and insurance on a New Haven rental unit Plaintiff has rented for nine years. See Bradley, NNH-CV22-5054091-S, Doc. 100.30 (“Small Claims Writ and Notice of Suit”). According to Plaintiff, in response to her demand to remove an insurance charge from her monthly 1 rent, Storquest terminated her lease and ordered her to retrieve her property or lose it. Id. at 2. In the state action, during the months of July and August of 2022, Plaintiff filed a series of motions, and the Connecticut Superior Court denied each one. See Bradley, NNH-CV22-5054091-S, Doc. 102 (“Motion for Order for Disclosure or to Accept Service”), Doc.

102.10 (“Order,” denying No. 102, for “failure to attach the Proof of Delivery to the Statement of Service regarding Priority Mail”), Doc. 103 (“Motion for Order” - “Cease and Desist,” to “order Storquest to Cease and Desist the breaking of the lease agreement”), Doc. 103.10 (“Order,” denying motion [103] because “issues raised will be addressed at trial”), Doc. 104 & 106 (“Motion[s] for Transfer” of case to Milford, Connecticut, court), Doc. 104.10 & 106.10 (“Order[s],” denying transfer of case to Milford because venue in Milford would be “improper” ), Doc. 105 (“Motion for Default Judgment”), Doc. 105.10 (“Order,” denying request for default without prejudice in light of

Plaintiff’s failure to attach Proof of Delivery of service, Doc. 102.10). Plaintiff has also filed five requests for “Compliance,” asking the state court to, inter alia, order Storquest to pay the small claim of $5,000 and to set a date for Plaintiff to resume her lease and pay storage rent without insurance). Bradley, NNH-CV22-5054091-S, Doc. 107.00-111.00. The state court has filed no responsive pleading to those five “Compliance” requests, and the action remains pending. In the present federal action, filed in this Court on August 31, 2022, Plaintiff’s Complaint requests injunctive relief against the New Haven Superior Court in her state “small claims” action, alleging irreparable harm “due to the repeated deliberate lack of due process” and the “use of [the

state] court clerk to implement unlawful orders.” Doc. 1, at 2 (capitalization omitted). In particular, she requests this Court to order the Superior Court to order Storquest to cease its “fraudulent billing,” “remove [the] charge of insurance,” clarify that “insurance [is] not required,” and allow the 2 “disabled Plaintiff to continue as a storage customer in accordance with [the] lease.” Id. at 3 (capitalization omitted). She asserts that if she does not receive the requested injunctive relief, she will lose the possessions she has stored in her Storquest rental unit. Id. at 2-3. In addition, rather than awaiting trial or further order of the state court, Plaintiff asks this

Court to reverse the state court’s rulings on Plaintiff’s motion for default judgment and motion for order for disclosure. Id. at 3-4. Furthermore, in light of her disagreement with these rulings, Plaintiff questions the integrity of Small Claims Magistrate Ruth Beardsley, alleging that her decisions “reflect [her] deceptive intent.” Id. at 21. The Court herein resolves Plaintiff’s request for injunctive relief. II. DISCUSSION Pursuant to the “Anti-Injunction Act,” “[a] court of the United States 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. See also Mitchum v. Foster, 407 U.S. 225, 230 (1972) (“[T]he national policy forbid[s] federal courts to stay or enjoin pending state court proceedings except under special circumstances.”) (citation omitted). This statute thus generally prohibits federal court injunctions of state court proceedings in progress. “The policy of the anti-injunction statute, 28 U.S.C. § 2283, is to prohibit enjoining of state court suits except in those situations where the real or potential conflict threatens the very authority

of the federal court.” Vernitron Corp. v. Benjamin, 440 F.2d 105, 108 (2d Cir. 1971), cert. denied, 402 U.S. 987 (1971). “Proceedings in state courts[, thus,] should normally be allowed to continue unimpaired by intervention of the lower federal courts, with relief from error, if any, through the 3 state appellate courts and ultimately [the Supreme] Court.” United States v. Schurkman, 728 F.3d 129, 135 (2d Cir. 2013) (quoting Atl. Coast Line R.R. Co. v. Bhd. of Locomotive Eng'rs, 398 U.S. 281, 287 (1970)). The “explicit wording” of § 2283 and “the fundamental principle of a dual system of courts” indicates that “[a]ny doubts as to the propriety of a federal injunction against state court

proceedings should be resolved in favor of permitting the state courts to proceed in an orderly fashion to finally determine the controversy.” Schurkman, 728 F.3d at 135 (quoting Atl. Coast Line R.R. Co., 398 U.S. at 297). Where, as in the present case, the litigation involves private parties, the policy of § 2283 becomes “much more compelling” because the requested injunction “threatens to draw the two judicial systems [– state and federal –] into conflict.” Studebaker Corp. v. Gittlin, 360 F.2d 692, 697 (2d Cir. 1966). As the Second Circuit noted, “[t]here is no reason why [a] state court cannot or

should not determine issues of fact and state law relevant thereto as they come up in the state litigation.” Ret. Sys. of Ala. v. J.P. Morgan Chase & Co., 386 F.3d 419, 429 (2d Cir. 2004) (quoting Vernitron, 440 F.2d at 108). Based upon the facts presented, the case at bar implicates no express exception to 28 U.S.C. § 2283. There is thus no applicable statute by Congress that would allow this Court to enjoin the state court in this instance. Moreover, the state court poses no threat to this Court’s jurisdiction, and there is no federal judgment “to protect or effectuate” with such an injunction. 28 U.S.C. § 2283.

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Related

Denton v. Hernandez
504 U.S. 25 (Supreme Court, 1992)
Studebaker Corporation v. Richard D. Gittlin
360 F.2d 692 (Second Circuit, 1966)
Hill v. Curcione
657 F.3d 116 (Second Circuit, 2011)
United States v. Schurkman
728 F.3d 129 (Second Circuit, 2013)
Cuoco v. Moritsugu
222 F.3d 99 (Second Circuit, 2000)
Gallop v. Cheney
642 F.3d 364 (Second Circuit, 2011)
Mitchum v. Foster
407 U.S. 225 (Supreme Court, 1972)

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Bradley v. Superior Court of New Haven, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bradley-v-superior-court-of-new-haven-ctd-2022.