Crisp v. United States Department of Education

District Court, D. Arizona·Decided October 8, 2021·No. 2:21-cv-01649·Unknown

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Shirley Diane Crisp, No. CV-21-01649-PHX-SMB

10 Plaintiff, ORDER

11 v.

12 United State Department of Education,

13 Defendant. 14 15 Pending before the Court is Plaintiff’s Complaint. (Doc. 1.) For reasons set forth 16 below, the Court will dismiss the complaint with leave to amend. 17 I. BACKGROUND 18 Ms. Crisp’s complaint alleges that she had her identity stolen and that someone 19 fraudulently incurred student loan debt in her name. (Id. at 6.) Those purportedly 20 fraudulent loans are now in default, and the IRS has garnished her tax refund of $5,818.00. 21 (Id.) Although it is not entirely clear, she appears to be seeking (1) declaratory judgment 22 that she has been “a victim of identity theft,” (2) an injunction against future garnishment 23 of her pay checks or tax returns related to this issue, (3) reimbursement of the previously 24 garnished tax refund in the amount of $5,818.00 plus interest, and (4) to “not be held 25 responsible for [the fraudulent] student loan debt.” (Id.) Ms. Crisp has also filed an 26 Application for Leave to Proceed In Forma Pauperis. (Doc. 2.) 27 Ms. Crisp’s filed her complaint against the United State Department of Education 28 (“DOE”) using a pro se civil case form. (See Doc. 1 at 1–5.) Where the form designates 1 the basis for jurisdiction, Ms. Crisp checked the federal question box but left blank the 2 diversity of citizenship box. (Id. at 3.) However, in the federal question jurisdiction 3 section, she neglected to “[l]ist the specific federal statues, federal treaties, and/or 4 provisions of the Unites State Constitution that are at issues in this case.” (Id.) Instead, 5 Ms. Crisp filled out the citizenship details for herself and the DOE under the section for 6 pleading diversity jurisdiction. (Id. at 3–4.) But Ms. Crisp neglected to list the amount in 7 controversy or explain why she believed it exceeds $75,000. (Id. at 4.) In other words, 8 Ms. Crisp has not properly pled either federal question or diversity jurisdiction, as 9 explained below. 10 II. LEGAL STANDARD 11 In pro se filings, the Court must review the complaint to determine whether the 12 action: (i) is frivolous or malicious; 13 (ii) fails to state a claim on which relief may be granted; or 14 (iii) seeks monetary relief against a defendant who is immune from such relief. 15

16 See 28 U.S.C. § 1915(e)(2)(B). 17 A complain is frivolous or fails to state a claim if there is no subject matter 18 jurisdiction. “[L]ack of subject matter jurisdiction cannot be waived, and the court is under 19 a continuing duty to dismiss an action whenever it appears that the court lacks jurisdiction.” 20 Augustine v. United States, 704 F.2d 1074, 1077 (9th Cir. 1983); see Fed. R. Civ. P. 21 12(h)(3). Issues with jurisdiction “may be facial or factual.” Safe Air for Everyone v. 22 Meyer, 373 F.3d 1035, 1039 (9th Cir. 2004). A facial issue is one where “the allegations 23 contained in a complaint are insufficient on their face to invoke federal jurisdiction.” Id. 24 In determining whether a facial jurisdictional issue exists, the court “accept[s] the 25 plaintiff’s allegations as true and draw[s] all reasonable inferences in the plaintiff’s favor” 26 and then “determines whether the allegations are sufficient as a legal matter to invoke the 27 court’s jurisdiction.” Leite v. Crane Co., 749 F.3d 1117, 1121 (9th Cir. 2014). 28 When a plaintiff does not meet the burden of showing that the court has subject- 1 matter jurisdiction, the court must dismiss the action. Fed. R. Civ. P. 12(h)(3); see also 2 United States v. Cotton, 535 U.S. 625, 630 (2002) (“Because subject-matter jurisdiction 3 involves a court’s power to hear a case, it can never be forfeited or waived.”). Additionally, 4 a court must dismiss an in forma puaperis case if it determines that the Plaintiff “seeks 5 monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915. 6 However, unless it is “‘absolutely clear’ that [a plaintiff] could not cure [a 7 complaint’s] deficiencies by amendment,” the court will give the plaintiff opportunity to 8 do so. See Jackson v. Barnes, 749 F.3d 755, 767 (9th Cir. 2014) (citations omitted); Fed. R. 9 Civ. P. 15(a)(2) (“The court should freely give leave [to amend] when justice so requires.”). 10 III. DISCUSSION 11 Ms. Crisp’s complaint suffers from jurisdictional and other procedural ailments. 12 A. Subject-Matter Jurisdiction 13 Ms. Crisp has not properly pled subject-matter jurisdiction—either diversity or 14 federal question. “Federal courts are courts of limited jurisdiction” and may only hear 15 cases as authorized by the Constitution or Congress. Kokkonen v. Guardian Life Ins. Co. 16 of Am., 511 U.S. 375, 377 (1994). A court has subject-matter jurisdiction (1) over claims 17 that “aris[e] under the Constitution, laws, or treaties of the United States” and (2) over 18 “civil actions where the matter in controversy exceeds the sum or value of $75,000, 19 exclusive of interest and costs, and is between” diverse parties. 28 U.S.C. §§ 1331, 1332. 20 Because our jurisdiction is limited, it is presumed that a cause lies outside of it, and the 21 burden of establishing jurisdiction is on the party asserting it. Kokkonen, 511 U.S. at 377. 22 Ms. Crisp indicated that she was pleading federal question jurisdiction by checking 23 that box on her complaint form, but she never provided the federal statute or constitutional 24 provision on which her case rests. Thus, she has not met the burden of establishing federal 25 question jurisdiction. Similarly, Ms. Crisp left the diversity judication portion of the form 26 incomplete. She filed out the party’s citizenship but never listed the amount in controversy. 27 The only claim for financial relief that she clearly pled is in her attached letter, which 28 demanded reimbursement of her garnished tax return, amounting $5,818.00 plus interest— 1 far short of the more than $75,000 requirement for diversity jurisdiction. 2 Therefore, Ms. Crisp has not properly pled diversity or federal question jurisdiction 3 and has left the Court without clarity as to what form of subject-matter jurisdiction she is 4 attempting to plead. Consequently, dismissal is required. Fed. R. Civ. P. 12(h)(3). 5 B. Sovereign Immunity 6 Under 28 U.S.C. § 1915(e)(2)(B)(iii), the Complaint must also be dismissed if it 7 seeks monetary damages against a defendant who is immune from such relief. Ms. Crisp 8 explains her grievance against the DOE but has not pointed to a waiver of sovereign 9 immunity that would subject the DOE to suit.

Free access — add to your briefcase to read the full text and ask questions with AI

Crisp v. United States Department of Education, (D. Ariz. 2021).

Crisp v. United States Department of Education (Crisp v. United States Department of Education) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

United States v. Nordic Village, Inc.
503 U.S. 30 (Supreme Court, 1992)
Federal Deposit Insurance v. Meyer
510 U.S. 471 (Supreme Court, 1994)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
United States v. Cotton
535 U.S. 625 (Supreme Court, 2002)
Richard Augustine v. United States
704 F.2d 1074 (Ninth Circuit, 1983)
Richard McCarthy v. United States
850 F.2d 558 (Ninth Circuit, 1988)
KG Urban Enterprises, LLC v. Patrick
693 F.3d 1 (First Circuit, 2012)
Frederick Jackson v. Michael Barnes
749 F.3d 755 (Ninth Circuit, 2014)
Douglas Leite v. Crane Company
749 F.3d 1117 (Ninth Circuit, 2014)
Safe Air for Everyone v. Meyer
373 F.3d 1035 (Ninth Circuit, 2004)