And because he lacks a lawyer, I cut him extra slack. If I can “reasonably read [his] pleadings to state a valid claim, ” I must. Morgan v. Scott, 83 F.Supp.3d 616, 620 (D. Del. 2015). But even on that relaxed standard, Enigwe fails to plead the necessary facts for a counterfeiting claim.
If not raised in the first action, a compulsory counterclaim is barred in subsequent litigation. Morgan v. Scott, 83 F. Supp. 3d 616, 624 (D. Del. 2015). The "operative question" in determining if a claim is a compulsory counterclaim is whether the counterclaim "bears a logical relationship to an opposing party's claim."
Additionally, because Plaintiffs are proceeding pro se, the Court construes their pleadings liberally. See Morgan v. Scott, 83 F. Supp. 3d 616, 620 (D. Del. 2015) ("Pro se pleadings, 'however inartfully pleaded,' must be held to 'less stringent standards than formal pleadings drafted by lawyers.'" (quoting Haines v. Kerner, 404 U.S. 519, 520-21 (1972))). Lastly, the Court notes that in adjudicating a Rule 12(b)(6) motion, the scope of what may be considered is necessarily constrained: a court may "consider only the complaint, exhibits attached to the complaint, matters of public record, as well as undisputedly authentic documents if the complainant's claims are based upon these documents."
Finally, federal courts routinely apply the Younger doctrine to cases seeking to enjoin state court eviction proceedings. See Morgan v. Scott, 83 F. Supp. 3d 616, 623 (D. Del. 2015) (collecting cases). IV. CONCLUSION
Old Republic Union Ins. Co. v. Tillis Trucking Co., 124 F.3d 1258, 1261 (11th Cir. 1997) (citing Middlesex County Ethics Comm., 457 U.S. at 432); see also Dixon v. Haworth, No. 8:09-cv-1017-T-30EAJ, 2009 WL 4730546, at *1 (M.D. Fla. Dec. 4, 2009). If indeed the state court proceeding is still ongoing, Younger abstention would appear to be warranted in this case. See e.g., Morse v. Fed. Nat'l Mortgage Assoc., 2019 WL 1177989, at *6 (E.D. Tex. Feb. 12, 2019) (an eviction proceeding "involves an important state interest, namely the state's interest in the security of title to real estate."); Abreu v.Ochoa-Salazar, 2017 WL 1900729, at *2 (D. N.J. May 8, 2017) (court declines to exercise jurisdiction over state eviction action because Younger elements satisfied); Morgan v. Scott, 83 F. Supp. 3d 616, 623 (D. De. 2015) ("Federal courts have routinely held that the Younger doctrine bars them from enjoining State court eviction proceedings." (listing cases)); Haynie v. New York City Housing Auth., 2015 WL 502229, at *2 (E.D. N.Y. Feb. 5, 2015) (where "there is no suggestion that [Plaintiff] is unable to assert his due process claims in the state court proceedings," Younger abstention is appropriate); Prindable v Assoc. of Apartment Owners of 2987 Kalakaua, 304 F. Supp. 2d 1245, 1262 (D. Hawaii 2003) (pursuant to Younger abstention, court declined to exercise jurisdiction over state eviction claims).
Under the Younger abstention doctrine, a federal court is required to abstain from exercising jurisdiction where: (1) there is an ongoing state proceeding, (2) which implicates important state interests, and (3) there is an adequate opportunity to raise any relevant federal questions in the state proceeding. Morgan v. Scott, 83 F.Supp.3d 616 (D. Del. 2015). The doctrine applies to state-court proceedings until all appellate remedies have been exhausted unless it falls within an exception.