Eisenmann-Aviles v. Municipality of CoamoEisenmann-Aviles v. Municipality of Coamo
OPINION AND ORDER
I. Introduction
Daniel Reinaldo Eisenmann-Avilés (Plaintiff) filed this action against the Municipality of Coamo (Municipality) and various other defendants (collectively Defendants),1 seeking judicial intervention to prevent the Municipality from exercising its eminent domain powers to appropriate a parcel of real property held by Plaintiff. Plaintiff seeks equitable and legal relief under
Shortly after filing the Complaint, Plaintiff moved for a preliminary injunction. (ECF No. 13). That motion was referred to the Honorable United States Magistrate
II. Factual Background
The Municipality of Coamo is a town in the south of Puerto Rico. In November 2021, Plaintiff purchased a parcel of real property in Barrio Pasto, an administrative subdivision of Coamo. (ECF No. 10 at 8 ¶ 19). At the far end of Barrio Pasto sits La Cuesta, a small, low-income community. (ECF No. 73 at 3).2
Barrio Pasto is serviced by several local aqueducts, since Puerto Rico Aqueduct and Sewer Authority (PRASA) infrastructure does not extend throughout the entire subdivision. Historically, La Cuesta relied on an aqueduct that drew from a local spring.
To keep water flowing to La Cuesta, the community formed an agreement with one Ramón Sánchez (Sánchez), who was then the owner of a parcel of land at issue in this litigation.3 Sánchez allowed the community to access a deep water well on his 51-acre property; in turn, the Municipality invested in the well by developing infrastructure to extract the water and deliver it to the people. (ECF No. 73 at 3-4). Such infrastructure included the construction of a utility room and the placement of an electrical meter so that the La Cuesta community could connect the well to its water distribution system. (ECF No. 10 at 9 ¶¶ 24-25). At the same time, the Municipality of Coamo assisted community members with incorporating La Cuesta as a formal subdivision of Coamo, and a community association representing La Cuesta was formed. (ECF No. 73 at 4).
In 2021, for approximately $70,000, Plaintiff acquired the parcel from an investment firm that had purchased the land from a portfolio of foreclosed properties. (ECF No. 73 at 4-5). Negotiations over the community‘s use of the well then commenced. As Plaintiff sought to revert the use of the well to his private control, he encountered resistance on multiple fronts. According to the Complaint, when Plaintiff asserted his private property rights over the well, the Mayor of Coamo invoked his responsibility to provide water to [the La Cuesta] community and assured Plaintiff that
Between 2022 and 2025, Plaintiff engaged in negotiations with the Municipality and members of the La Cuesta community over access to the well. (ECF No. 73 at 5); (ECF No. 10 at 9-13). In several proposals made by Plaintiff, the community would have had access to the well in exchange for a fee. (ECF No. 1-3 at 108-112). After protracted negotiations, the parties failed to reach an agreement over those terms. (ECF No. 73 at 5-6). In the meantime, Plaintiff had allegedly cut off community access to the well. As a result, La Cuesta went without regular access to water for approximately two years and three months, during which time the Municipality sent more than 500 water trucks to the community to provide water. (ECF No. 73 at 5).
The sustained period of water insecurity plaguing La Cuesta posed a serious threat to public health. The Municipality therefore decided to exercise its eminent domain power, initiating a condemnation action in the Superior Court of Coamo (Superior
Plaintiff identifies two alleged flaws in the condemnation proceedings. First, Plaintiff alleges that, when the Municipality initiated condemnation proceedings against his property, he was never properly served notice of the lawsuit. (ECF No. 10 at 13 ¶ 60); (ECF No. 13 at 2). Plaintiff argues that such actions violated the due process clause of the Fifth and Fourteenth Amendments of the United States Constitution. (ECF No. 82 at 5). Second, Plaintiff alleges that the Superior Court failed to observe the requirements of the Servicemembers Civil Relief Act (SCRA), which provides procedural protections for military service members like Plaintiff to guard against the risk of a default judgment while they are on active duty. (ECF No. 13 at 2) (citing
Plaintiff filed an interlocutory appeal to the Puerto Rico Court of Appeals, which was denied. (ECF No. 73 at 8). Plaintiff then filed a petition for a writ of certiorari to the Supreme Court of Puerto Rico, which has not yet issued a ruling on the petition. (ECF No. 73 at 9 n.6). In the meantime, at the request of Plaintiff, the Superior Court stayed the case until May 2026.
On November 10, 2025, Plaintiff filed this case. (ECF No. 1). Shortly thereafter, he moved for preliminary injunctive relief, requesting that the Court prohibit the enforcement of the August 20, 2025 Superior Court order and the occupation or use of his property. (ECF No. 13).4 The Municipality opposed, arguing that the relief sought
That request was referred to Judge Ramos for a Report and Recommendation. (ECF No. 15). After holding an evidentiary hearing, Judge Ramos issued a Report and Recommendation on March 5, 2026, recommending that Plaintiff‘s request for a preliminary injunction be denied and that the Court dismiss or stay the case. (ECF No. 73 at 12-18). Plaintiff filed a timely objection to the Report and Recommendation. (ECF No. 82).
III. The Report and Recommendation
In the Report and Recommendation, Judge Ramos carefully addressed Plaintiff‘s request to enjoin enforcement of [a state court order] he claims violate[d] his federal constitutional and statutory rights. (ECF No. 73 at 11). According to Judge Ramos, Plaintiff faced two significant doctrinal hurdles obstructing his path to relief: the Anti-Injunction Act and Younger abstention doctrine.
As Judge Ramos explained in the Report and Recommendation, the Anti-Injunction Act provides that [a] court of the United States may not grant an injunction to stay proceedings in a State court except as expressly authorized by Act of Congress, or where necessary in aid of its jurisdiction, or to protect or effectuate its judgments. (ECF No. 73 at 13) (quoting
As to the issue of abstention, Judge Ramos concluded that Younger abstention is warranted in this case. (ECF No. 73 at 14 n.10). Observing the principles of equity, comity, and federalism, from which Younger abstention doctrine arose, Judge Ramos determined that all three requirements of Younger were met. First, Judge Ramos found that Younger abstention applies in the context of ongoing eminent domain proceedings in state court. (ECF No. 73 at 15) (citing Duty Free Shop, Inc. v. Administración de Terrenos de Puerto Rico, 889 F.2d 1181, 1182 (1st Cir. 1989)). Second, Judge Ramos
OBJECTIONS TO THE REPORT AND RECOMMENDATION
In the written objection to the Report and Recommendation, Plaintiff objected to the recommended application of Younger abstention doctrine. First, Plaintiff cited to the recent Supreme Court case Knick v. Township of Scott, Pennsylvania, 588 U.S. 180 (2019), arguing that Knick squarely rejected the notion that federal courts must abstain from hearing federal takings claims simply because a state eminent domain process exists or is ongoing. (ECF No. 82 at 7). In addition, Plaintiff emphasized that Younger abstention is the exception, not the rule. (quoting Sprint Communications, Inc. v. Jacobs, 571 U.S. 69, 77 (2013)). According to Plaintiff, the instant case falls squarely within the recognized limitations on Younger doctrine for proceedings that are conducted in bad faith, that fail to provide an adequate opportunity to vindicate federal rights, or that display extraordinary circumstances . . . that threaten irreparable injury to federally protected rights. (ECF No. 82 at 11) (citing Middlesex County Ethics Committee v. Garden State Bar Ass‘n, 457 U.S. 423, 435 (1982)). Specifically, Plaintiff argues that the eminent domain proceedings in the state court were characterized by bad faith because Defendants pursued the expropriation proceeding despite knowledge of Plaintiff‘s active duty military status and without complying with the procedural
IV. Analysis
This case raises a question that tests the proper boundaries of our federal system: under what circumstances may a federal court intervene in ongoing state-level judicial proceedings to vindicate a claim of federal right? Plaintiff argues that immediate federal intervention is necessary, lest the state be allowed to assume control of private property . . . while disregarding the procedural protections mandated by federal law and the Constitution. (ECF No. 82 at 2). Defendants disagree, arguing that federal intervention in the state-level proceedings would defy the principles of comity that order the relationship between federal and local tribunals. (ECF No. 103 at 4).
Recently, in Knick v. Township of Scott, Pennsylvania, the Supreme Court set out to resolve a Catch-22 posed to litigants who sought to challenge state-level condemnation proceedings on federal law grounds. 588 U.S. 180 (2019). Prior to Knick,
To resolve this quandary, Knick did away with the requirement that a federal takings plaintiff exhaust state remedies before reaching federal court. Knick, 588 U.S. at 190 (The Fifth Amendment right to full compensation arises at the time of the taking, regardless of post-taking remedies that may be available to the property owner.). The takings claim raised by Plaintiff is therefore ripe for resolution, as Plaintiff argues in his objection to the Report and Recommendation. However, although Plaintiff‘s claims have accrued, that alone does not guarantee that the exercise of federal jurisdiction is proper at this time.
The Court agrees with the Report and Recommendation that Younger doctrine requires the Court to abstain from presiding over the instant case pending the resolution of the parallel state-level proceedings. First, as the Report and Recommendation correctly
The fact that Plaintiff‘s claim has accrued does not change this analysis: as a recent decision from this District held under analogous circumstances, abstention may be appropriate in the context of a federal civil rights claim challenging a state court eminent domain action even where the federal claim has accrued. See Concilio de Salud Integral de Loiza, Inc. v. Municipality of Rio Grande, Civ. No. 21-0510, 2025 WL 1604075 (D.P.R. June 6, 2025) (applying Pullman abstention). Concilio de Salud Integral arose from an alleged taking of private property by the Municipality of Río Grande, which initiated a state level condemnation proceeding against Concilio de Salud Integral after the latter had filed a federal suit challenging the taking as a violation of federal constitutional law. Id. at *1-2. While acknowledging that Knick had dissolved the exhaustion and ripeness hurdles that had previously been an obstacle to such claims, the Court nevertheless found in Concilio de Salud Integral that Knick [did] not limit a district court‘s ability to abstain from a federal takings claim under the Pullman doctrine because of a related eminent domain action that was pending in state court. Id. at *3 (quoting CKC Properties, LLC v. Town of Mt. Pleasant, Civ. No. 23-4489, 2024 WL 39067, at *7 (D.S.C. Jan. 3, 2024)) (citing Gearing v. City of Half Moon Bay, 54 F.4th 1144, 1148 (9th Cir. 2022)). [R]ipeness, the Court explained, goes to when a claim accrues for purposes of judicial review[,] while [a]bstention, on the other hand, allows courts to stay claims that have already accrued. Id. (internal quotations and citations omitted). The Court then went on to find that all Pullman requirements [were] satisfied[.] Id. at *4. Because here all of the requirements for Younger abstention are satisfied, the Court finds that the same result is warranted here.
Furthermore, even if Younger abstention were not applicable, the Court would apply Pullman abstention. The Supreme Court has directed that, in certain circumstances, a federal court should abstain from reaching a federal constitutional issue where it is likely that the dispute could be resolved (or narrowed) in state court under state law. Greenwood, LLC v. City of Newton, 128 F.4th 1, 4 (1st Cir. 2025) (citing R.R. Comm‘n v. Pullman Co., 312 U.S. 496, 501 (1941)). This doctrine, known as Pullman abstention, allows courts to avoid resolving . . . federal questions by encouraging a state-law determination first, and serves to avoid federal-court error in deciding state-law questions antecedent to federal constitutional issues. Id. (internal quotations and citations omitted).
Under the [Pullman] doctrine, declining to exercise jurisdiction is warranted where (1) substantial uncertainty exists over the meaning of the state law in question, and (2) settling the question of state law will or may well obviate the need to resolve a significant federal constitutional question. Batterman v. Leahy, 544 F.3d 370, 373 (1st Cir. 2008). This case meets both of those requirements. First, in the parallel state-level
V. Conclusion
For the foregoing reasons, the Court will abstain from adjudicating this case until the complete resolution of the parallel state case. Accordingly, 13 Motion for a Preliminary Injunction is DENIED and this case is hereby STAYED.
IT IS SO ORDERED.
In San Juan, Puerto Rico, this 21st day of July, 2026.
/s/ María Antongiorgi-Jordán
MARIA ANTONGIORGI-JORDAN
UNITED STATES DISTRICT JUDGE