Crawford v. Clay (MAG+)

CourtDistrict Court, M.D. Alabama
DecidedOctober 7, 2024
Docket2:24-cv-00167
StatusUnknown

This text of Crawford v. Clay (MAG+) (Crawford v. Clay (MAG+)) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Crawford v. Clay (MAG+), (M.D. Ala. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

MARTIN CRAWFORD, ) ) Plaintiff, ) ) v. ) CASE NO. 2:24-CV-167-MHT-KFP ) DARRELL LADNIER, et al., ) ) Defendants. )

RECOMMENDATION OF THE MAGISTRATE JUDGE

Before the Court is Defendants Shelton Hamilton and Darrell Ladnier’s (the Federal Defendants) Motion to Dismiss for Lack of Jurisdiction. Doc. 12. Plaintiff did not file any opposition to the motion.1 On September 19, 2024, the Court held a hearing on the motion. Upon consideration, the undersigned finds the motion should be GRANTED, as explained below. I. STANDARD OF REVIEW Federal district courts are courts of limited jurisdiction and are authorized by the United States Constitution and by statute to hear only certain types of actions. United States v. Rivera, 613 F.3d 1046, 1049 (11th Cir. 2010). Federal courts are obligated to inquire into subject matter jurisdiction sua sponte “at the earliest possible stage in the proceedings.” Univ. of S. Ala. v. Am. Tobacco Co., 168 F.3d 405, 410 (11th Cir. 1999). “It

1 Plaintiff did communicate with counsel for the Federal Defendants about the motion, and he initially represented that he had no opposition to it. Doc. 14-1. Subsequently, Plaintiff represented to the Federal Defendants that he did oppose the motion. Doc. 16-1. is to be presumed that a cause lies outside this limited jurisdiction, and the burden of establishing the contrary rests upon the party asserting jurisdiction.” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994) (internal citations omitted). Rule 12(h)(3)

of the Federal Rules of Civil Procedure requires dismissal if a court at any time determines that it lacks subject matter jurisdiction. Fed. R. Civ. P. 12(h)(3). “Whether a claim ‘arises under’ a federal law ‘is generally determined by the well- pleaded complaint rule, which provides that federal jurisdiction exists only when a federal question is presented on the face of the plaintiff’s properly pleaded complaint.’” Hill v.

BellSouth Telecomms., Inc., 364 F.3d 1308, 1314 (11th Cir. 2004) (quoting Smith v. GTE Corp., 236 F.3d 1292, 1310 (11th Cir. 2001)). When a case is removed from state to federal court, federal courts must strictly construe removal statutes and resolve all doubts in favor of remand. Miedema v. Maytag Corp., 450 F.3d 1322, 1328–30 (11th Cir. 2006). II. BACKGROUND

Plaintiff filed this action in the district court of Montgomery County, Alabama. Doc. 1-1 at 13–7. He asserted claims against the Federal Defendants along with claims against Walter Scott, Dawn Clay, and Nicholas Dowdell alleging they owe him $11,000 in damages for “labor or services or equipment or material” which was “furnished for a work of improvement” that he was subcontracted to complete. Doc. 1-1 at 13–17. On March 14,

2024, the Federal Defendants removed the case to this Court pursuant to 28 U.S.C. § 1442(a)(1). Doc. 1 at 1–2. Thereafter, they filed the motion under consideration here. Doc. 12. III. DISCUSSION The Federal Defendants are federal employees who work at the Maxwell Air Force Base.2 Doc. 12 at 2. The Base hired contractor Provision Contracting Services, LLC to

remove trees. Doc. 12 at 2. On September 28, 2023, Provision Contracting entered into a contract with the United States Government for the tree removal, and Darrell Ladnier was the “Contracting Officer” listed on the contract. Doc. 12-1 at 2. Provision Contracting subcontracted with Plaintiff’s company, Crawford and Sons Tree Surgery, to perform the work. Doc. 12 at 2. Plaintiff alleges that the tree removal work was performed, but

Crawford and Sons was not paid. Doc. 1-1 at 3, 8. Plaintiff brought this action against the Federal Defendants, the Provision Contracting defendants (Clay and Dowdell), and Walter Scott seeking to recover for work Crawford and Sons performed on the tree removal subcontract. Doc. 1-1 at 13–17. The Federal Defendants argue that “because the United States has not consented to

be sued on contract claims of this sort in federal district courts,” that this claim is not properly before this Court. Doc. 12 at 1. The Federal Defendants further argue that because “the United States has not waived sovereign immunity for claims brought by subcontractors like Mr. Crawford,” this Court lacks subject matter jurisdiction. Id.3

2 At the hearing on the motion, Plaintiff conceded that the Federal Defendants are federal government officials sued in that capacity. 3 At the time of removal on March 14, 2024, there were still three unserved defendants. See Notice of Service at 6, 12, 14 (No. DV-2024-900749.00). Following removal, Defendants Dawn Clay and Nicholas Dowdell were served in the Montgomery County district court. See Notice of Service at 19, 21 (No. DV- 2024-900749.00). Nothing in the record in this Court indicates that defendants Dawn Clay and Nicholas Dowdell were served with notice of the removal of the case to this Court. Doc. 1. Defendant Walter Scott was served—before or since removal. See Notice at 22 (No. DV-2024-900749.00). A. Claims against the United States “The Tucker Act, 28 U.S.C. § 1346(a)(2), and the Contract Disputes Act [the CDA] of 1978, 41 U.S.C. §§ 602(a), 607(g)(1), 609(a)(1), provide that the United States District

Courts have no jurisdiction over suits against the United States founded on contracts with the United States.” Mark Dunning Indus., Inc. v. Cheney, 934 F.2d 266, 269 (11th Cir. 1991). Contract claims against the United States that involve contracts with the United States can only be brought in the United States Claims Court or the “agency’s board of contract appeals.” Id.

Statutes, like the Tucker Act and the Contract Disputes Act, that waive “sovereign immunity must be strictly construed in favor of the sovereign.” Winter v. FloorPro, Inc., 570 F.3d 1367, 1370 (Fed. Cir. 2009) (quoting Orff v. United States, 545 U.S. 596, 601– 02 (2005)). “[T]he CDA is ‘a statute waiving sovereign immunity, which must be strictly construed.’” Id. (quoting Cosmic Constr. Co. v. United States, 698 F.2d 1389, 1390 (Fed.

Cir. 1982)). “[T]he provisions of the CDA apply only to ‘contractors’”; therefore, because “subcontractors are generally not in privity of contract with the government,” they typically cannot bring suits under the CDA. Id. at 1370–71. Further, under the CDA, there is no support for finding that “third-party beneficiary subcontractors are [] ‘contractors,’” as defined by the statute. Id. at 1372 (citing JGB Enters., Inc. v. United States, 63 Fed. Cl.

319, 330–31 (2004)). Additionally, the Tucker Act has its own privity requirement that gives the United States Court of Federal Claims jurisdiction over “any claim against the United States founded . . .

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