Does the domestic relations exception apply to a claim for injunctive relief?

MultiRegion, United States of America

The following excerpt is from Thomas v. Martin-Gibbons, No. 20-3124 (2nd Cir. 2021):

jurisdiction so long as there is no obstacle to their full and fair determination in state courts." Am. Airlines, 905 F.2d at 14; see also Deem v. DiMella-Deem, 941 F.3d 618, 623-25 (2d Cir. 2019).

The plaintiffs' claims for injunctive relief address the awarding of custody of J.O., and therefore those claims are barred by the domestic relations exception doctrine to the extent the claims are based on state law and invoke federal diversity jurisdiction. To the extent the claims are based on federal law, the district court did not err in abstaining from exercising jurisdiction. See Am. Airlines, 905 F.2d at 14. The claims "begin and end in a domestic dispute," and "[s]tates are better suited to that adjudication." Schottel v. Kutyba, No. 06-1577, 2009 WL 230106, at *1 (2d Cir. Feb. 2, 2009) (summary order).

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