Ford v. Board of Healing Arts

District Court, E.D. Missouri·Decided December 1, 2023·No. 4:23-cv-01337·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

JAMIE SUE FORD, ) ) Plaintiff, ) ) v. ) Case No. 4:23-CV-1337 SPM ) BOARD OF HEALING ARTS, ) ) Defendant. )

MEMORANDUM AND ORDER

This matter is before the Court on self-represented plaintiff Jamie Sue Ford’s second motion for leave to proceed in forma pauperis. ECF No. 7. Having reviewed her amended filing, the Court will grant the request and permit her to proceed in this action without prepaying fees and costs. Additionally, for the reasons discussed below, plaintiff will be directed to show cause as to why her complaint should not be dismissed for lack of subject matter jurisdiction. Second Motion to Proceed In Forma Pauperis On October 24, 2023, plaintiff filed the instant civil action with a blank Application to Proceed in District Court without Prepaying Fees or Costs. See ECF No. 2. On October 25, 2023, the Court reviewed the Application, but was unable to determine whether plaintiff met the economic requirements for in forma pauperis status because it did not provide any of the necessary financial information. ECF No. 4. Consequently, she was directed to submit a completed Application or pay the full filing fee no later than November 8, 2023. Id. Plaintiff did not timely comply and, on November 16, 2023, the Court denied her request to proceed in forma pauperis, and directed her to pay the full $402 filing fee. ECF No. 6. The Court subsequently received, on November 21, 2023, a second Application to Proceed in District Court without Prepaying Fees or Costs. See ECF No. 7. The financial information provided reflects that plaintiff is not currently employed and has no available funds or assets. Therefore, the Court will grant plaintiff’s second request to proceed in this civil matter without

prepaying fees or costs. See 28 U.S.C. § 1915(a)(1) (the Court may authorize the commencement or prosecution of a civil action without prepayment of fees if the plaintiff demonstrates he or she “is unable to pay such fees or give security therefor.)” Order Show Cause Subject matter jurisdiction refers to a court’s power to decide a certain class of cases. LeMay v. U.S. Postal Serv., 450 F.3d 797, 799 (8th Cir. 2006). “Federal 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). See also Gunn v. Minton, 568 U.S. 251, 256 (2013) (“Federal courts are courts of limited jurisdiction, possessing only that power authorized by Constitution and statute”).

The presence of subject matter jurisdiction is a threshold requirement that must be assured in every federal case. Kronholm v. Fed. Deposit Ins. Corp., 915 F.2d 1171, 1174 (8th Cir. 1990). See also Sanders v. Clemco Indus., 823 F.2d 214, 216 (8th Cir. 1987) (“The threshold requirement in every federal case is jurisdiction and we have admonished the district court to be attentive to a satisfaction of jurisdictional requirements in all cases”). As such, the issue of subject matter jurisdiction may be raised at any time, by any party or the court. Gray v. City of Valley Park, Mo., 567 F.3d 976, 982 (8th Cir. 2009). Federal courts have subject matter jurisdiction over both federal question cases and diversity of citizenship cases. See Auto-Owners Ins. Co. v. Tribal Court of Spirit Lake Indian Reservation, 495 F.3d 1017, 1020 (8th Cir. 2007) (finding subject matter jurisdiction is lacking if neither diversity of citizenship nor federal question jurisdiction applies); and McLaurin v. Prater, 30 F.3d 982, 984-85 (8th Cir. 1994) (noting Congress has directed that district courts shall have jurisdiction in both federal question and diversity cases).

Federal question jurisdiction gives district courts “original jurisdiction over civil actions arising under the Constitution, laws, or treaties of the United States.” Griffioen v. Cedar Rapids & Iowa City Ry. Co., 785 F.3d 1182, 1188 (8th Cir. 2015). See also 28 U.S.C. § 1331. Whether a claim arises under federal law is determined by reference to the “well-pleaded complaint.” Great Lakes Gas Transmission Ltd. P’ship v. Essar Steel Minn. LLC, 843 F.3d 325, 329 (8th Cir. 2016). The well-pleaded complaint rule provides that jurisdiction exists only when a federal question is presented on the face of a plaintiff’s properly pleaded complaint. Markham v. Wertin, 861 F.3d 748, 754 (8th Cir. 2017). See also Thomas v. United Steelworkers Local 1938, 743 F.3d 1134, 1139 (8th Cir. 2014) (“Under the well-pleaded complaint rule, a federal question must exist on the face of the plaintiff’s properly pleaded complaint in order to establish federal question subject

matter jurisdiction”). Plaintiff’s complaint must establish “either that federal law creates the cause of action or that the plaintiff’s right to relief necessarily depends on the resolution of a substantial question of federal law.” Williams v. Ragnone, 147 F.3d 700, 702 (8th Cir. 1998). “Under 28 U.S.C. § 1332(a), district courts have original diversity jurisdiction over civil actions when the matter in controversy exceeds $75,000, without considering interest and costs, and when the citizenship of each plaintiff is different from the citizenship of each defendant.” Ryan ex rel. Ryan v. Schneider Nat. Carriers, Inc., 263 F.3d 816, 819 (8th Cir. 2001). A complaint making a good faith allegation of the jurisdictional amount is sufficient to confer jurisdiction. Scottsdale Ins. Co. v. Universal Crop Prot. All., LLC, 620 F.3d 926, 931 (8th Cir. 2010). However, a “complaint will be dismissed if it appears to a legal certainty that the claim is really for less than the jurisdictional amount.” Id. See also Kopp v. Kopp, 280 F.3d 883, 884 (8th Cir. 2002). “The legal certainty standard is met where the legal impossibility of recovery is so certain as virtually to negative the plaintiff’s good faith in asserting the claim.” Peterson v. The Travelers Indem. Co.,

867 F.3d 992, 995 (8th Cir. 2017).

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280 F.3d 883 (Eighth Circuit, 2002)
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785 F.3d 1182 (Eighth Circuit, 2015)
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