Franklin v. Walmart Service Department Mechanic

CourtDistrict Court, E.D. Wisconsin
DecidedJune 27, 2024
Docket2:24-cv-00766
StatusUnknown

This text of Franklin v. Walmart Service Department Mechanic (Franklin v. Walmart Service Department Mechanic) is published on Counsel Stack Legal Research, covering District Court, E.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Franklin v. Walmart Service Department Mechanic, (E.D. Wis. 2024).

Opinion

EUANSITTEERDN S DTAISTTERSI CDTIS OTFR WICITS CCOONUSRITN

TINIKA FRANKLIN,

Plaintiff, Case No. 24-cv-0766-bhl v.

WALMART SERVICE DEPARTMENT MECHANIC,

Defendant. ______________________________________________________________________________

SCREENING ORDER ______________________________________________________________________________ On June 20, 2024, Plaintiff Tinika Franklin, proceeding pro se, filed a complaint against the Walmart Auto Service Department and one or more unnamed mechanics. (ECF No. 1.) That same day, she also filed a motion for leave to proceed without prepayment of the filing fee or in forma pauperis (IFP). (ECF No. 2.) The Court has authority to allow a litigant to proceed IFP if it determines that (1) the litigant is unable to pay the costs of commencing the action and (2) the action is not frivolous, does not fail to state a claim, and is not brought against an immune defendant. C.f. 28 U.S.C. § 1915(a)(1), (e)(2). The Court will consider each of these issues in turn. THE MOVANT’S INDIGENCY Franklin reports that she is unmarried and unemployed, with $1,200 in monthly Social Security income. Against this she lists monthly expenses totaling $1,119, including $375 in support to her fifteen-year-old granddaughter, $300 for rent, and $444 for other household expenses. Franklin reports as her only asset a 2015 Dodge Journey but does not provide an estimate of its value. Given her reliance on Social Security as her sole source of income, her lack of liquid assets, and her monthly expense obligations, which approach her total income, the Court concludes that Franklin is sufficiently indigent for a fee waiver. SCREENING THE COMPLAINT In screening a pro se complaint, the Court applies the liberal pleading standards embraced by the Federal Rules of Civil Procedure. To survive screening, the complaint must comply with the Federal Rules and state at least plausible claims for which relief may be granted. To state a cognizable claim, a plaintiff is required to provide a “short and plain statement of the claim showing that [he] is entitled to relief.” Fed. R. Civ. P. 8(a)(2). It must be at least sufficient to provide notice to each defendant of what he or she is accused of doing, as well as when and where the alleged actions or inactions occurred, and the nature and extent of any damage or injury the actions or inactions caused. “[T]he pleading standard Rule 8 announces does not require ‘detailed factual allegations,’ but it demands more than an unadorned, the-defendant-unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). “[T]he tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions. Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id. A complaint must contain sufficient factual matter, accepted as true, to “state a claim to relief that is plausible on its face.” Twombly, 550 U.S. at 570. “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 556). “Factual allegations must be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555 (citation omitted). If the complaint fails to allege sufficient facts to state a claim on which relief may be granted, it must be dismissed. See Luevano v. Wal-Mart Stores, Inc., 722 F.3d 1014, 1018 (7th Cir. 2013). ALLEGATIONS OF THE COMPLAINT On May 18, 2024, Franklin visited a Walmart in Germantown, Wisconsin to have the front left tire of her Dodge Journey changed after a screw got stuck in the tire. (ECF No. 1 at 4.) Walmart employees began servicing her vehicle, but then told Franklin that they couldn’t remove a lug nut and instructed her to take the vehicle to Fleet Farm to have them loosen the lug nut so Walmart could complete the tire change. (Id.) Franklin did as instructed and then took her car back to Walmart. After several hours, Franklin was informed that Walmart had broken her lug nut and could not fix or replace it. (Id. at 6.) Franklin was repeatedly assured by Walmart staff that it was safe for her to drive the vehicle with a lug nut missing, so she drove home. (Id.) She then lent the vehicle to her daughter on May 20, 2024, only for the same tire to come entirely off the vehicle while Franklin’s daughter was driving her granddaughter to school. (Id.) Franklin was forced to call for a tow truck and when it arrived the driver informed her that all the lug nuts were missing from her tire. (Id. at 5.) Walmart’s alleged mishandling of her tire change caused additional damage to Franklin’s car, for which she received an estimate of $2,774 to repair. Franklin does not state what relief she requests or under what legal theory. She cites Rogers v. Missouri Pac. R. Co., 352 U.S. 500 (1957), a Supreme Court case analyzing the negligence standard under the Federal Employers’ Liability Act. (Id. at 7.) Franklin also cites Elliot v. Jones, Case No. 4:06CV89-MP/AK, 2009 U.S. Dist. LEXIS 91125 (N.D. Fla. Sept. 1, 2009), a report and recommendation from a magistrate judge in the Northern District of Florida that the plaintiff’s complaint alleging deliberate indifference under the Eighth Amendment pursuant to 42 U.S.C. § 1983 should be dismissed. (Id.) ANALYSIS Federal courts are courts of limited jurisdiction. This Court has the authority to consider and decide civil cases “arising under the Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331. And it has the authority to consider and decide civil cases between citizens of different states if the amount in controversy is greater than $75,000. 28 U.S.C. § 1332. The former is called “federal question” jurisdiction and the latter “diversity jurisdiction.” “The party invoking federal jurisdiction bears the burden of establishing that it exists.” Sykes v. Cook Inc., 72 F.4th 195, 205 (7th Cir. 2023). Thus, the Court may only exercise jurisdiction over this case if Franklin plausibly alleges a claim arising under federal law, or a state law claim for more than $75,000 against defendants from states different from her own. Because Franklin has done neither, her complaint must be dismissed for lack of subject-matter jurisdiction. With respect to federal question jurisdiction, Franklin cites to federal law, including cases under the Federal Employers’ Liability Act and 42 U.S.C. § 1983, but none of the federal law she invokes is applicable to the facts she alleges. The Federal Employers’ Liability Act, 45 U.S.C. § 51 et seq., applies only to railroad companies.

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Related

Rogers v. Missouri Pacific Railroad
352 U.S. 500 (Supreme Court, 1957)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Lynch v. Northeast Regional Commuter Railroad
700 F.3d 906 (Seventh Circuit, 2012)
Tara Luevano v. Walmart Stores, Incorporated
722 F.3d 1014 (Seventh Circuit, 2013)
Eddie R. Bradley v. Village of University Park, IL
929 F.3d 875 (Seventh Circuit, 2019)

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Bluebook (online)
Franklin v. Walmart Service Department Mechanic, Counsel Stack Legal Research, https://law.counselstack.com/opinion/franklin-v-walmart-service-department-mechanic-wied-2024.