FEDERAL APPEALS COURT AFFIRMS STAY OF FORECLOSURE FRAUD CASE

Earlier this month the United States Court of Appeals for the Eleventh Circuit affirmed the Middle District’s order staying disposition of a lawsuit filed by pro se litigant Robert Fiedler “against Wells Fargo Bank, MTGLQ Investors, and US Bank Trust, alleging state law foreclosure fraud, abuse of process, civil conspiracy to commit foreclosure fraud, and intentional infliction of emotional distress.” Fiedler v. Wells Fargo Bank N.A., No. 25-10717, 2025 U.S. App. LEXIS 29706, at *1 (11th Cir. Nov. 13, 2025). Fiedler sought punitive damages in the amount of $2 million per defendant. 1

Fiedler’s federal claims stemmed from a 2015 foreclosure action initiated in state court. There are no details about the state court proceeding or the merits of the federal case, but the Middle District found that Fiedler’s federal claims overlapped with the state court proceedings which were (1) ongoing, (2) implicated an “important state interest,” and (3) that Fiedler had an adequate opportunity to raise his federal claims in the state court action. 2 Because these three elements were satisfied, the Middle District found the Younger Abstention applied and stayed Fiedler’s federal lawsuit.

Fielder appealed that decision to the Eleventh Circuit but, confusingly, argued that his request for monetary damages did not interfere with the state proceeding so the Younger Abstention did not apply and “the court should not have dismissed [his] case.” 3 Noting that the damages claim was stayed, not dismissed, and that Fiedler appeared to argue in favor of the Middle District’s ruling, the Eleventh Circuit found Fiedler failed to demonstrate the court abused its discretion by staying the federal case. 4

The Court did clarify that Fiedler’s amended complaint “did not request injunctive or declaratory relief [so] none of his claims should be considered dismissed.” The Eleventh Circuit affirmed the stay of the Middle District case pending resolution of the state foreclosure action. This decision further solidifies this country’s long-standing policy, articulated in Younger, that the “National Government will fare best if the States and their institutions are left free to perform their separate functions in their separate ways.” 5

1 Fiedler, at *1. Future references to this case are to this citation until indicated otherwise.

2 Fiedler, at *3. Under the United States Supreme Court decision in Younger v. Harris, 401 U.S. 37, 91 S. Ct. 746 (1971), if these three elements are met the federal court will abstain from ruling on a matter until the resolution of the state court matter. Fiedler, at *3. Courts refer to this as the “Younger Abstention.” Id.

3 Fiedler, at *3-4.

4 Fiedler, at *4. Future references to this case are to this citation until indicated otherwise.

5 Younger v. Harris, 401 U.S. 37, 43, 91 S. Ct. 746, 750 (1971).

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