Brown-Hyatt v. Brenner, 1:25-cv-01657

Nadia Brown-Hyatt is the owner and resident of 3707 Liberty Heights Avenue in Baltimore, Maryland.
Foreclosure proceedings against her were initiated in Maryland state court by TH MSR Holdings, LLC, through Substitute Trustees.
Brown-Hyatt filed motions in state court challenging the foreclosure, claiming lack of standing and lack of subject matter jurisdiction.
The state court had not yet ruled on plaintiff's pending motions at the time of this federal filing.
Brown-Hyatt sought a temporary restraining order and preliminary injunction from the federal court to halt the scheduled foreclosure sale, alleging due process violations.
The federal district court reviewed the filings without a hearing and considered whether it had jurisdiction to intervene.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Appropriateness of federal intervention under Younger	Federal court should intervene to stop foreclosure	State action ongoing; abstention required	Abstain; no federal intervention
Standing of TH MSR Holdings to foreclose	No assignment of promissory note; no standing	(Not directly briefed)	Issue for state court to resolve
Adequacy of state forum for constitutional claims	Federal court necessary to protect due process rights	State court can hear these	State court is adequate
Entitlement to emergency injunctive relief	Will suffer irreparable harm without federal injunction	(Not directly briefed)	Not reached due to Younger abstention

Younger v. Harris, 401 U.S. 37 (1971) (federal courts should abstain from interfering in ongoing state proceedings except in special circumstances)
Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (2008) (sets out the modern four-factor test for preliminary injunctions)
Middlesex Cnty. Ethics Comm. v. Garden State Bar Ass'n, 457 U.S. 423 (1982) (clarifies the three criteria for Younger abstention in civil cases)
Nivens v. Gilchrist, 444 F.3d 237 (4th Cir. 2006) (articulates the test for Younger abstention in the Fourth Circuit)