Lahey v. Nys Unified Court System, Monroe County Family Court

• Court: District Court, District of Columbia
• Decided: November 14, 2025
• Docket: Civil Action No. 2025-2606
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

BRITTANNI LAHEY, ) ) Plaintiff, ) ) v. ) Civil Action No. 1:25-cv-02606 (UNA) ) ) NYS UNIFIED COURT SYSTEM, ) MONROE COUNTY FAMILY ) COURT, et al., ) ) Defendants. )

MEMORANDUM OPINION

Currently before the Court is Plaintiff’s pro se Complaint, ECF No. 1, and Application for

Leave to Proceed in forma pauperis (“IFP App.”), ECF No. 2. The Court grants Plaintiff’s IFP

Application, and for the reasons explained below, it dismisses this matter without prejudice.

Plaintiff, a resident of New York, sues the New York State Unified Court System (Monroe

County Family Court), the Monroe County Public/Conflict Defender’s Office, the Bivona Child

Advocacy Group, the Legal Aid Society of Rochester, and the University of Rochester Medical

Center, all of whom are also located in New York. See Compl. at 3–4. The common link between

the Defendants is their involvement in custody proceedings involving Plaintiff’s daughter, filed in

Monroe County Family Court. See id. at 3–57. Plaintiff challenges the legality and validity of

numerous actions taken, arising from determinations rendered in those proceedings, and she seeks

damages and equitable relief. See id.

At root, Plaintiff demands that this Court review and intervene in local New York court

proceedings, but this the Court is without subject matter jurisdiction to do so. Federal district

courts generally lack jurisdiction to review or interfere with judicial decisions by state courts and local bodies, and Plaintiff cannot circumvent that prohibition by bringing this matter under the

auspices of federal legal authority. See Richardson v. District of Columbia Court of Appeals, 83

F.3d 1513, 1514 (D.C. Cir. 1996) (citing District of Columbia v. Feldman, 460 U.S. 462, 476

(1983) and Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923)). Applicable here, the domestic

relations exception generally deprives a federal district court of the power to issue or modify child

custody determinations. See Ankenbrandt v. Richards, 504 U.S. 689, 703 (1992); see also Bennett

v. Bennett, 682 F.2d 1039, 1042 (D.C. Cir. 1982) (explaining that domestic relationship exception

divests federal court of jurisdiction to “resolve parental conflicts over the custody

of . . . children”). State custody determinations must be contested in the local court where the

proceedings were held. See Bennett, at 682 F.2d at 1042–43 (explaining that child custody issues

are uniquely suited to resolution in local courts).

Assuming arguendo that this Court could exercise subject matter jurisdiction over

Plaintiff’s claims, venue in this District is improper. Generally, venue in a civil action is proper

only in (1) the district where any defendant resides, if all defendants reside in the same state in

which the district is located, (2) in a district in which a substantial part of the events or omissions

giving rise to the claim occurred (or a substantial part of the property that is the subject of the

action is situated), or (3) in a district in which any defendant may be found, if there is no district

in which the action may otherwise be brought. See 28 U.S.C. § 1391(b). As pleaded, this action

bears no connection to the District of Columbia.

For all of these reasons, the Complaint, ECF No. 1, and this case, are dismissed without

prejudice. A separate Order accompanies this Memorandum Opinion.

TREVOR N. McFADDEN Date: November 14, 2025 United States District Judge