TUCSON (LN) — U.S. District Judge John J. Tuchi denied a motion to stay civil rights proceedings pending a state court eviction ruling, holding that the federal claims regarding retaliation and emotional distress were not sufficiently parallel to the state lease dispute.

U.S. District Judge John J. Tuchi rejected arguments by defendants Michael Mongini, Brittney K. Walsh, Cottonwood Springs RV, LLC and Happy Jack Lodge LLC that the federal case should wait for the outcome of Yavapai County Superior Court case no. S1300CV202580488.

The defendants argued that a stay was warranted because both cases arose underlying facts and issues. They pointed to the Superior Court case, which Plaintiff Daniel T. Doria filed on December 1, 2025, based on his lease agreement and eviction.

Doria filed the instant federal action on January 12, 2026.

Tuchi applied the eight-factor test from Colorado River Water Conservation Dist. v. U.S., 424 U.S. 800 (1976), to determine if "exceptional circumstances" justified the stay.

The judge found the first threshold requirement for a stay—parallelism—was not met.

"Here, the Superior Court Case and this matter are not sufficiently parallel," Tuchi wrote.

The federal case includes claims for retaliation and coercion under the Fair Housing Act, conspiracy to interfere with civil rights under 42 U.S.C. § 1985(3), abuse of process, and intentional infliction of emotional distress.

The Superior Court case involves breach of lease, unlawful eviction under the Arizona Recreational Vehicle Long-Term Rental Space Act, and injunctive relief.

Tuchi noted that even if the state court resolved the eviction, the federal court would still have "further to do" because the federal claims would remain.

"The decision to invoke Colorado River necessarily contemplates that the federal court will have nothing further to do in resolving any substantive part of the case," the judge wrote, citing Moses H. Cone Mem'l Hosp. v. Mercury Constr. Corp., 460 U.S. 1, 28 (1983).

The judge also weighed other factors against a stay.

He found the inconvenience of a two-hour drive between Phoenix and Yavapai County was minimal, especially since many proceedings were held telephonically.

Tuchi rejected the argument that piecemeal litigation was a concern, noting that the federal claims did not turn on whether the eviction was proper under the lease or state law.

"Defendants present no 'special concern' that elevates the possibility of limited cross-over of facts and evidence to something that justifies a stay," the judge wrote.

The only factor weighing in favor of a stay was the order in which the forums obtained jurisdiction. The Superior Court case was filed first and had progressed to summary judgment motion practice, while the federal case had not even surpassed the answering stage.

However, Tuchi concluded that this single factor did not outweigh the others.

The judge also dismissed defendants' arguments about foreclosure and improper accommodations as better suited for a motion to dismiss under Federal Rule of Civil Procedure 12.

Tuchi denied the motion to stay proceedings.