Miguel Angel Quinones-Camacho v. Toledo Properties Owner B LLC, et al.

• Court: District Court, N.D. Ohio
• Decided: March 19, 2026
• Docket: 3:26-cv-00628
• Status: Unknown

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION

Miguel Angel Quinones-Camacho, Case No. 3:26-cv-628

Plaintiff,

v. MEMORANDUM OPINION AND ORDER

Toledo Properties Owner B LLC, et al.,

Defendants.

I. INTRODUCTION This matter is before me on Plaintiff Miguel Angel Quinones-Camacho’s motion for a temporary restraining order and preliminary injunction. (Doc. No. 4). The motion follows the March 16, 2026 service of a writ of restitution, which is scheduled for execution on March 18, 2026, at Quinones-Camacho’s residence in Toledo, Ohio. (Id. at 1). Quinones-Camacho seeks a temporary restraining order to stay the execution of the writ, a preliminary injunction to prohibit his removal from the premises, and asks I preserve the status quo until I conduct a hearing on his request for a preliminary injunction. (Id. at 3). For the reasons stated below, I deny the motion and dismiss this action for lack of jurisdiction. II. BACKGROUND Quinones-Camacho is a tenant in Toledo, Ohio, and currently a defendant in an eviction action at Toledo Municipal Court. (Doc. No. 1 at 1, 3). He alleges that Defendants Toledo Properties Owner B LLC, Monarch Investment and Management Group LLC, Trey Coburn, and various “Doe” defendants improperly added late fees and other charges to his account, on top of his regular monthly rent. (Id. at 2). According to Quinones-Camacho, Defendants initiated eviction proceedings after he requested an audit and documentation to prove the validity of these fees. (Id. at 2-3). He contends this was done in retaliation for the request. (Id. at 3). On March 16, 2026, Quinones-Camacho filed suit in this Court, alleging Defendants’ conduct violates § 3617 of the Fair Housing Act and several Ohio laws. (Id. at 4-5). Quinones-

Camacho further alleges there is an accelerated eviction schedule following service of the writ of restitution which violates his Fourteenth Amendment right to due process. (Id. at 5). III. DISCUSSION Quinones-Camacho is currently engaged in an active eviction case in Toledo Municipal Court. See Toledo Prop. Owner B LLC d/b/a Abbey Run Apartments v. Quinones-Camacho, CVG-26- 00793. That posture directly implicates the abstention principles articulated in Younger v. Harris, 401 U.S. 37, 44-45 (1971). Under Younger, federal courts must refrain from intervening in pending state judicial proceedings that implicate important state interests, absent a showing of “extraordinary circumstances.” Id. Consistent with these principles, where a litigant is already in an ongoing state proceeding involving important state matters, he may not circumvent that process by filing a parallel action in federal court, raising claims that could have been raised in the state forum. Borkowski v. Fremont Inv. and Loan, 368 F. Supp. 2d 822, 828 (N.D. Ohio 2005) (citing Watts v. Burkhart, 854 F.2d

839, 844-48 (6th Cir. 1988)). “If the state defendant files such a case, Younger abstention requires the federal court to defer to the state proceedings.” Caroll v. City of Mount Clemens, 139 F.3d 1072, 1074- 75 (6th Cir. 1998) (citing Watts, 854 F.2d at 844-48). The applicability of Younger abstention turns on three considerations: “‘(1) whether the underlying proceedings constitute an ongoing state judicial proceeding; (2) whether the proceedings implicate important state interests; and (3) whether there is an adequate opportunity in the state proceedings to raise a constitutional challenge.’” Loch v. Watkins, 337 F.3d 574, 578 (6th Cir. 2003) (quoting Tindall v. Wayne Cnty. Friend of the Ct., 269 F.3d 533, 538 (6th Cir. 2001)) (further citation omitted). With respect to the third factor, the burden rests on the plaintiff “to show ‘that state procedural barred presentation of [its] claims.’” Pennzoil Co. v. Texaco, Inc., 481 U.S. 1, 14 (1987) (quoting Moore v. Simms, 442 U.S. 415, 432 (1979)) (alteration in Pennzoil Co.). Where a plaintiff has

not attempted to raise such claims in the state proceeding, a federal court should presume that the state forum provides an adequate remedy unless there is “unambiguous authority to the contrary.” Id. at 15. Each of these factors supports abstention in this case. First, Quinones-Camacho is actively engaged in eviction proceedings in Toledo Municipal Court. Second, “eviction proceedings pending in a municipal court implicate important state interests.” McCoy v. Park Lane Manor LLC, No. 5:24CV01843, 2025 WL 72611, at *3 (N.D. Ohio Jan. 10, 2025) (further citations omitted). See also Hackel v. N. Hill Farms I, No. 25-10779, 2025 WL 935568, at *2 (E.D. Mich. Mar. 27, 2025) (citing cases). Third, there is no indication in the pleadings that Quinones-Camacho is precluded from asserting federal claims concerning the eviction in state court. Permitting this action to proceed would risk undue interference with the ongoing state eviction proceedings. Accordingly, I must abstain from exercising jurisdiction over Quinones- Camacho’s eviction-related claims, and he must pursue them in state court. IV. CONCLUSION For the reasons stated above, I deny Quinones-Camacho’s motion for a temporary restraining order and permanent injunction. (Doc. No. 4). Further, I grant Quinones-Camacho’s motion to proceed in forma pauperis, (Doc. No. 2), and I dismiss Quinones-Camacho’s complaint without prejudice. (Doc. No. 1).

So Ordered.

s/ Jeffrey J. Helmick United States District Judge