Ali v. American University of Antigua, Inc.

CourtDistrict Court, S.D. New York
DecidedMarch 24, 2025
Docket1:25-cv-02065
StatusUnknown

This text of Ali v. American University of Antigua, Inc. (Ali v. American University of Antigua, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ali v. American University of Antigua, Inc., (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK MOHAMED ABO ALI, Plaintiff, 1:25-CV-2065 (LTS) -against- AMERICAN UNIVERSITY OF ANTIGUA, ORDER OF DISMISSAL INC.; MANIPAL EDUCATION AMERICAS, WITH LEAVE TO REPLEAD LLC, Defendants. LAURA TAYLOR SWAIN, Chief United States District Judge: Plaintiff Mohamed Abo Ali, of Colonia, New Jersey, who is appearing pro se, filed this action invoking the court’s diversity jurisdiction. He sues: (1) American University of Antigua, Inc. (“AUA”), which he describes as “a private, foreign, for-profit educational institution incorporated in the [S]tate of Florida” that has “its university campus located” in Antigua; and (2) Manipal Education Americas, LLC (“MEA”), which he describes as “a limited liability company incorporated in the State of New York.” (ECF 1, at 3.) Plaintiff describes MEA as “the parent company of AUA and [that it] oversees [AUA’s] financial, administrative, and operational functions”; he alleges that MEA has its principal place of business in New York, New York. (Id. at 3-4.) In his complaint, Plaintiff seeks, among other relief, unspecified damages and declaratory relief, as well as injunctive relief, including “a Temporary Restraining Order and Preliminary Injunction[] compelling [AUA and MEA] to immediately release [his] diploma and all necessary documentation for [Educational Commission for Foreign Medical Graduates (“ECFMG”)] certification to prevent irreparable harm to his residency prospects.” (Id. at 12.) He has also filed, with his complaint, an order of show cause for a preliminary injunction and a temporary restraining order (“OTSC”) in which he seeks, among other relief, the following immediate injunctive relief: (1) “a Temporary Restraining Order compelling [AUA and MEA] to immediately release [his] diploma and transcript directly to ECFMG within 24 hours”; (2) “a Non-Retaliation Order [p]rohibiting [AUA and MEA], their officers, employees, agents, and

representatives from taking any retaliatory action against [him] for seeking this relief.” (ECF 6, at 11.) By order dated March 13, 2025, the Court granted Plaintiff’s request to proceed in forma pauperis (“IFP”), that is, without prepayment of fees. For the reasons set forth below, the Court dismisses this action for lack of subject matter jurisdiction, but grants Plaintiff 30 days’ leave to replead his claims in an amended complaint. STANDARD OF REVIEW The Court must dismiss an IFP complaint, or any portion of the complaint, that is frivolous or malicious, fails to state a claim on which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B); see Livingston v. Adirondack Beverage Co., 141 F.3d 434, 437 (2d Cir. 1998). The Court must also

dismiss a complaint when the Court lacks subject matter jurisdiction of the claims raised. See Fed. R. Civ. P. 12(h)(3). While the law mandates dismissal on any of these grounds, the Court is obliged to construe pro se pleadings liberally, Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009), and interpret them to raise the “strongest [claims] that they suggest,” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474 (2d Cir. 2006) (internal quotation marks and citations omitted, emphasis in original). BACKGROUND Plaintiff alleges the following: Plaintiff is a graduate of AUA’s medical school. “He completed 1 year of pre-clinical medicine at AUA’s campus in Antigua and 3.5 years in the U.S., including two years of clinical rotations at AUA-affiliated hospitals in New York.” (ECF 1, at 4.) Plaintiff completed his requirements for graduation on September 13, 2024; 14 days later, on September 27, 2024, he registered for medical residency placement. “Plaintiff requires his diploma from AUA to obtain ECFMG certification, a mandatory requirement to start residency

at any of the 17 hospitals he interviewed with.” (Id.) Approximately one month later, on October 29, 2024, he “received an email from [AUA and MEA] with FedEx tracking information for his Medical Diploma and official transcript.” (Id.) On November 18, 2024, however, he received from either AUA, MEA, or both an email “stating that the [United States Department of Education (“DOE”)] has required AUA to cancel Plaintiff’s Title IV [loan] disbursement[s] for his Fall 2023 semester . . . and that AUA has arranged for a private loan through Richland Bank to replace the canceled disbursements.” (Id.) AUA “has been under HCM2 [DOE oversight], which is the most severe level of oversight from the [DOE’s Office of Federal Student Aid (“FSA”),] starting [in the] Fall [of] 2023, [and] coinciding with” Plaintiff’s Fall 2023 semester attending AUA. (Id.) That level of

oversight “requires institutions to cover student aid disbursements upfront and then seek reimbursement from” the DOE. (Id.) AUA and MEA “failed to request Plaintiff’s federal loan through FSA properly and [are] subsequently attempting to compel payment from Plaintiff by wrongfully withholding his degree without clarification, prior notice, or due process.” (Id.) They “have failed to provide any official documentation or federal directive from the DOE confirming this requirement despite Plaintiff’s numerous requests for documentation or specific reference to the alleged mandate to cancel his Title IV loans.” (Id.) Since December 4, 2024, AUA’s and MEA’s “representatives have intentionally misled Plaintiff by providing conflicting instructions, directing him to complete unnecessary forms, and delaying responses while refusing to provide a clear resolution for obtaining a private loan.” (Id. at 5.) AUA and MEA have also “repeatedly and knowing made false claims to Plaintiff that he was not eligible for Title IV loans for [part of his academic career] when, in fact, Plaintiff was eligible for [those] loans, but [AUA and MEA] failed to request [them] properly.” (Id.) They

further “acted in bad faith and deliberately withheld information about [AUA’s] HCM2 designation and financial liability to pressure Plaintiff to obtain a private loan to pay tuition in order to receive his degree in time to participate in the residency match.” (Id.) “As a result of [AUA’s and MEA’s] actions, Plaintiff remains uncertified for residency, jeopardizing his medical career, and has a balance [owed to AUA and/or MEA] of $53,000.”1 (Id.) DISCUSSION A. Subject matter jurisdiction The court appears to lack subject matter jurisdiction to consider this action. The subject matter jurisdiction of the federal district courts is limited and is set forth generally in 28 U.S.C. §§ 1331 and 1332. Under these statutes, a federal district court has subject matter jurisdiction only when a “federal question” is presented or, when claims under state law are asserted under

the court’s diversity jurisdiction, when the plaintiff and the defendants are citizens of different States and the amount in controversy exceeds the sum or value of $75,000. “[I]t is common ground that in our federal system of limited jurisdiction any party or the court sua sponte, at any

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Bluebook (online)
Ali v. American University of Antigua, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ali-v-american-university-of-antigua-inc-nysd-2025.