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Newton v. Mizell

2009 WL 311854 (U.S. Dist. Ct. D. N.J. 2009) (Unpublished)

LANDLORD-TENANT; EVICTION; APPEALS — Lower federal courts are precluded from exercising appellate jurisdiction over final state-court judgments, including those involving eviction of a tenant.

Tenants engaged in a series of disputes with their landlord, culminating in the filing of an eviction action by the landlord. Specifically, the tenants alleged that a county agency had declared their apartment to be uninhabitable and defective. The tenants believed this abated their obligation to pay rent until the building defects were cured. They alleged that rather than proceeding to cure the defects, the landlord sought to expel them from the apartment. Two eviction actions were filed, but neither resulted in an eviction. The tenants then sued the landlord for relocation assistance and requested an order be issued that the landlord repair specific defects within their apartments. During the course of this action, the tenants came to believe that the presiding judge and landlord engaged in wrongful behavior contributing to issuance of a judgment of possession. The tenants appealed the judgment to the Appellate Division. The Appellate Division remanded the matter to the lower court, each time requesting that it provide supplemental opinions setting forth the jurisdictional basis upon which the tenants were being evicted. The lower court held that it had jurisdiction to order the eviction based upon an earlier complaint filed by the landlord that had been previously stayed as the result of bankruptcy proceedings in which the landlord was involved. On further appeal, the Appellate Division upheld the lower court’s ruling.

The tenants then sued in the United States District Court, asserting that the rulings of the state courts violated their federal statutory and Constitutional rights. The tenants asked that the federal court enjoin the eviction order. To the tenants’ dismay, the Court held that it had no jurisdiction to review the state court decision and dismissed the tenants’ complaint. It ruled that tenants’ claims were properly within the purview of the state court, as lower federal courts are prohibited from reviewing final state court judgments.


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