Opinion
CV-22-01473-PHX-MTL
10-21-2022
Nicholas Woodall, Plaintiff, v. Maricopa County, et al., Defendants.
ORDER
Michael T. Liburdi, United States District Judge
Federal courts are courts of limited jurisdiction, and it is presumed that the court lacks subject-matter jurisdiction unless the party asserting the claim satisfies his or her burden of establishing jurisdiction. Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994). The Court has an independent obligation to determine whether it has subject-matter jurisdiction. Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574, 583 (1999). Pursuant to Rule 12(h)(3) of the Federal Rules of Civil Procedure, “[i]f the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.” Although “a plaintiff's assertion of an invalid federal cause of action does not always implicate the existence of subject-matter jurisdiction,” dismissal for lack of subject-matter jurisdiction based on “the inadequacy of the federal claim” is proper “when the [federal] claim is so insubstantial, implausible, foreclosed by prior decisions of this Court, or otherwise completely devoid of merit as not to involve a federal controversy.” Robinson v. Aetna Life Ins. Co., No. CV-20-01830-PHX-DWL, 2021 WL 2138778, at *4 (D. Ariz. May 26, 2021) (quoting Steel Co. v. Citizens for a Better Env't, 523 U.S. 83, 89 (1998)). For the reasons stated below, the Complaint is dismissed for lack of subject-matter jurisdiction.
Plaintiff alleges that Defendants-Maricopa County and a Maricopa County Commissioner-improperly entered an injunction because they “did not request or require evidence” and “they did not obtain evidence provided by ‘petitioners' which showed their claims were lies.” (Doc. 1 at 9.) Plaintiff asserts two claims based off of the state court's injunction: (1) violations of due process and the 14th amendment and (2) negligence. (Doc. 1 at 12.)
Although Plaintiff asserts violations of the U.S. Constitution and a § 1983 claim in his first claim, the substance of this suit is an appeal of a state court decision. This is apparent from his pleading, which includes exhibits of the state court documents he is essentially appealing. (Id. at 16-22; Doc. 1-1 at 7-15.) A matter such as this must be handled by state courts because “[f]ederal courts are not courts of general jurisdiction; they have only the power that is authorized by Article III of the Constitution and the statutes enacted by Congress pursuant thereto.” Bender v. Williamsport Area Sch. Dist., 475 U.S. 534, 541 (1986). “The Rooker-Feldman doctrine is a well-established jurisdictional rule prohibiting federal courts from exercising appellate review over final state court judgments.” Reusser v. Wachovia Bank, N.A., 525 F.3d 855, 858-59 (9th Cir. 2008).
The Ninth Circuit has “recognized that ‘[t]he clearest case for dismissal based on the Rooker-Feldman doctrine occurs when a federal plaintiff asserts as a legal wrong an allegedly erroneous decision by a state court, and seeks relief from a state court judgment based on that decision.'” Id. at 859 (quoting Henrichs v. Valley View Dev., 474 F.3d 609, 613 (9th Cir. 2007)). This is precisely what is occurring here-Plaintiffs seek review and relief from a decision that occurred within the superior court. (Doc. 1.)
As for Plaintiff's second claim, he alleges “[n]egligent emotional harm of Restatement of Torts,” which is a state law claim. Although Plaintiff cites § 1983 in the caption of his second claim, the Court “has no jurisdiction over a claim, regardless of whether the claim is couched in federal terms, if the claim is patently without merit, or so insubstantial, improbable, or foreclosed by Supreme Court precedent as not to involve a federal controversy.” Ellis v. Corp., No. CV-18-4088-PHX-JAT, 2018 WL 6727259, at *3 (D. Ariz. Dec. 21, 2018) (internal citations and quotation marks omitted). Because Plaintiff asserts a state law claim, he must demonstrate, by a preponderance of the evidence, that diversity jurisdiction exists. Lew v. Moss, 797 F.2d 747, 74950 (9th Cir. 1986); see also McNatt v. Allied-Signal, Inc., 972 F.2d 1340 (9th Cir. 1992).
Diversity jurisdiction exists when there is complete diversity of citizenship between the plaintiff and the defendants and the amount in controversy exceeds $75,000, exclusive of interests and costs. 28 U.S.C. § 1332. A controversy meets this requirement when “all the persons on one side of it are citizens of different states from all the persons on the other side.” Strawbridge v. Curtiss, 7 U.S. 267 (1806). There is no complete diversity because Plaintiff is an Arizona citizen and asserts a state law claim against two Arizona defendants.
Accordingly, IT IS ORDERED dismissing Plaintiff's complaint (Doc. 1) for lack of subject matter jurisdiction.
IT IS FURTHER ORDERED denying Plaintiff's Application to Proceed in District Court Without Prepaying Fees or Costs (Doc. 2) and Motion for Consideration and Admittance (Doc. 5) as moot.