Brown v. JP Morgan Chase Bank

CourtDistrict Court, N.D. Texas
DecidedJuly 31, 2025
Docket3:25-cv-01462
StatusUnknown

This text of Brown v. JP Morgan Chase Bank (Brown v. JP Morgan Chase Bank) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown v. JP Morgan Chase Bank, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

TERRANCE TERRELL BROWN, SR., § PLAINTIFF, § § V. § CIVIL CASE NO. 3:25-CV-1462-S-BK § JP MORGAN CHASE BANK, ET AL., § DEFENDANTS. §

FINDINGS, CONCLUSIONS AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE

Pursuant to 28 U.S.C. § 636(b) and Special Order 3, this pro se civil action was referred to the United States magistrate judge for case management, including the entry of findings and a recommended disposition where appropriate. Upon review of the relevant pleadings and applicable law, this action should be DISMISSED WITHOUT PREJUDICE for lack of subject matter jurisdiction. I. BACKGROUND On June 9, 2025, Plaintiff Terrance Terrell Brown, Sr., filed a complaint against JP Morgan Chase Bank, Jamie Dimon, Citizens Bank and Trust Co., and Leo Brooks Lewis. Doc. 3. Brown then filed a motion for leave to amend along with a proposed amended complaint. Doc. 10; Doc. 11. At minimum, the original and amended complaints are inartfully pled and illogical. Brown alleges that Defendants owe him $25.5 million that was allegedly deposited in his account at JP Morgan Chase Bank and then transferred to Citizens Bank. Doc. 11 at 1-2; Doc. 3 at 1. Brown asserts that Defendants failed to release the funds to him in violation of his federal constitutional and statutory rights and a supposed contractual agreement. Doc. 11 at 2-3; Doc. 3 at 1. In the civil cover sheet, Brown checks the boxes for “U.S. Government Plaintiff” and diversity of citizenship as the jurisdictional bases. Doc. 3 at 2. He cites the following federal statutes: “National Bank Act of 164, Federal Serve Act of 1913, Glass-Steagall Act, Bank

Secrecy Act, Dodd Frank Wall & Consumer Protection Act of 2010.” Doc. 3 at 2. Brown also includes a demand for $25.5 million in damages. Doc. 3 at 2. Upon review, the Court concludes that subject matter jurisdiction is lacking. Thus, this action should be dismissed sua sponte.1 II. ANALYSIS The Court should always examine, sua sponte, if necessary, the threshold question of whether it has subject matter jurisdiction. The Lamar Co., L.L.C. v. Mississippi Transp. Comm'n, 976 F.3d 524, 528 (5th Cir. 2020); FED. R. CIV. P. 12(h)(3) (“If the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.”). Unless

otherwise provided by statute, a federal district court has subject-matter jurisdiction over (1) a federal question arising under the Constitution, a federal law, or a treaty, see 28 U.S.C. § 1331, or (2) a case in which there is complete diversity of citizenship between parties and the matter in controversy exceeds $75,000, see 28 U.S.C. § 1332. “Under the well-pleaded complaint rule, ‘a federal court has original or removal jurisdiction only if a federal question appears on the face of the plaintiff’s well-pleaded complaint; generally, there is no federal jurisdiction if the plaintiff properly pleads only a state law cause of action.’” Gutierrez v. Flores, 543 F.3d 248, 251-52

1 Because jurisdiction is lacking, the Court need not address the deficiencies in the amended complaint and motion for leave to proceed in forma pauperis. Doc. 11; Doc. 4. (5th Cir. 2008). Further, the plaintiff, as the party asserting subject-matter jurisdiction, bears the burden of establishing that subject matter jurisdiction exists. See Willoughby v. U.S. ex rel. U.S. Dep’t of the Army, 730 F.3d 476, 479 (5th Cir. 2013). The Court must also liberally construe pleadings filed by pro se litigants. See Erickson v. Pardus, 551 U.S. 89, 94 (2007) (noting pro se pleadings are “to be liberally construed” and “held

to less stringent standards than formal pleadings drafted by lawyers”); Cf. FED. R. CIV. P. 8(e) (“Pleadings must be construed so as to do justice.”). Even under the most liberal construction, however, Brown has not alleged facts that establish federal question or diversity jurisdiction. “A federal question exists only [in] those cases in which a well-pleaded complaint establishes either that federal law creates the cause of action or that the plaintiff’s right to relief necessarily depends on resolution of a substantial question of federal law.” Singh v. Duane Morris LLP, 538 F.3d 334, 337-38 (5th Cir. 2008) (citation and internal quotation marks omitted). Brown’s complaint, however, contains no factual allegations that support federal question jurisdiction. The complaint mentions in passing the U.S. Constitution, due process

clause, and federal statutes. But the mere mention of a federal law or bare assertion of a federal claim is not enough to obtain federal question jurisdiction. Indeed, “federal courts are without power to entertain claims otherwise within their jurisdiction if they are so attenuated and unsubstantial as to be absolutely devoid of merit . . . .” Hagans v. Levine, 415 U.S. 528, 536-37 (1974) (internal citation and quotation marks omitted); see Murphy v. Inexco Oil Co., 611 F.2d 570, 573 (5th Cir. 1980) (“[T]he assertion that the claim involves [a federal] question must be more than incantation.”). Also, Brown’s scant pleadings do not plead the existence of facts establishing subject- matter jurisdiction on the basis of diversity, which requires complete diversity of citizenship and a good faith claim for damages in excess of $75,000. 28 U.S.C. § 1332. Even if there is complete diversity of citizenship among the parties, Brown has arbitrarily alleged an excessive amount in damages, to meet the $75,000 jurisdictional amount in controversy. Doing so is prohibited and goes against the limited scope and purpose of the doctrine of diversity jurisdiction established by the United States Supreme Court. See Thomson v. Gaskill, 315 U.S. 442, 447

(1942); see also Harris v. Illinois Cent. R. Co., 220 F.2d 734, 736 (5th Cir. 1955) (damages for federal jurisdictional purposes must be estimated in good faith). As mentioned, Brown seeks $25.5 million in damages based on claims that the funds were deposited in his bank account and then transferred to another bank. However, his allegations, which lack any cognizable legal claim for relief, do not support that extraordinary request and, thus his damage claim lacks a good faith basis. Gaskill, 315 U.S. at 447 (“[T]he value of the ‘matter in controversy’ is measured not by the monetary result of determining the principle involved, but by its pecuniary consequence to those involved in the litigation.” ). Finally, because the complaint does not present an adequate basis for federal question

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Related

Singh v. Duane Morris LLP
538 F.3d 334 (Fifth Circuit, 2008)
Gutierrez v. Flores
543 F.3d 248 (Fifth Circuit, 2008)
Brewster v. Dretke
587 F.3d 764 (Fifth Circuit, 2009)
Thomson v. Gaskill
315 U.S. 442 (Supreme Court, 1942)
Hagans v. Lavine
415 U.S. 528 (Supreme Court, 1974)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Lamar Company, L.L.C. v. MS Transportation Commiss
976 F.3d 524 (Fifth Circuit, 2020)

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Brown v. JP Morgan Chase Bank, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-jp-morgan-chase-bank-txnd-2025.