J.R. v. Palos Verdes Peninsula Unified School District, Board of Education

CourtDistrict Court, C.D. California
DecidedOctober 5, 2021
Docket2:21-cv-07656
StatusUnknown

This text of J.R. v. Palos Verdes Peninsula Unified School District, Board of Education (J.R. v. Palos Verdes Peninsula Unified School District, Board of Education) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J.R. v. Palos Verdes Peninsula Unified School District, Board of Education, (C.D. Cal. 2021).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 J.R., a MINOR, by and through his Case No. 2:21-cv-07656-JAK-AFM 12 parent, SHARON E. RIZZI, and SHARON E. RIZZI, ORDER DISMISSING 13 Plaintiffs, COMPLAINT FOR LACK OF 14 SUBJECT MATTER v. JURISDICTION 15 PALOS VERDES PENINSULA 16 UNIFIED SCHOOL DISTRICT, et al., 17 Defendants. 18 19 20 On September 24, 2021, plaintiffs J.R., a minor, by and through his parent, and 21 Sharon E. Rizzi (“Rizzi”), a parent of J.R., filed a Complaint proceeding pro se. 22 (ECF No. 1-2.) The Complaint states that “J.R. is a minor child who attend [sic] 23 Palos Verdes Peninsula Unified School District” (“School District”). (Id. at 2.) 24 Plaintiffs purport to raise four claims, two pursuant to the Due Process Clause of the 25 Fourteenth Amendment of the United States Constitution and two pursuant to the 26 California Constitution. The pleading is signed by Sharon Rizzi, “individually and 27 on behalf of her minor child, J.R.” (Id. at 20.) Plaintiffs seek injunctive and 28 1 declaratory relief regarding a “mask mandate” issued by the School District, 2 including vacating the mandate. (Id. at 19-20.) Plaintiffs paid the full filing fee. 3 “‘Federal courts are courts of limited jurisdiction,’ possessing ‘only that power 4 authorized by Constitution and statute.’” Gunn v. Minton, 568 U.S. 251, 256 (2013) 5 (quoting Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994)). “A 6 federal court is presumed to lack jurisdiction in a particular case unless the contrary 7 affirmatively appears.” Stevedoring Servs. of Am., Inc. v. Eggert, 953 F.2d 552, 554 8 (9th Cir. 1992). To support federal question jurisdiction under 28 U.S.C. § 1331, a 9 plaintiff must present a federal question on the face of a complaint. See Rivet v. 10 Regions Bank, 522 U.S. 470, 475 (1998); Provincial Gov’t of Marinduque v. Placer 11 Dome, Inc., 582 F.3d 1083, 1086 (9th Cir. 2009) (for a federal court to exercise 12 federal question jurisdiction under 28 U.S.C. § 1331, “the federal question must be 13 disclosed upon the face of the complaint” (internal quotation marks omitted)). 14 “Absent a substantial federal question,” a “district court lacks jurisdiction,” and 15 claims that are “wholly insubstantial” or “obviously frivolous” are insufficient to 16 “raise a substantial federal question for jurisdictional purposes.” Shapiro v. 17 McManus, 577 U.S. 39, 45-46 (2015). 18 A federal court has “an ‘independent obligation’ to assess whether it has 19 jurisdiction” before proceeding to the merits of a case. Johnson v. Guzman Chavez, 20 141 S. Ct. 2271, 2292 (2021) (quoting Arbaugh v. Y&H Corp., 546 U.S. 500, 514 21 (2006)); see also Lance v. Coffman, 549 U.S. 437, 439 (2007) (“Federal courts must 22 determine that they have jurisdiction before proceeding to the merits.”). The Court 23 may dismiss a case summarily if the pleading presents an obvious jurisdictional issue. 24 See, e.g., Scholastic Entm’t, Inc. v. Fox Entm’t Grp., Inc., 336 F.3d 982, 985, 989 25 (9th Cir. 2003) (a court may dismiss sua sponte and without notice for lack of subject 26 matter jurisdiction without violating due process). 27 A federal court lacks subject matter jurisdiction if a plaintiff fails to establish 28 Article III standing. A “plaintiff bears the burden of proving” the existence of subject 1 matter jurisdiction and “must allege facts, not mere legal conclusions” to invoke the 2 court’s jurisdiction. Leite v. Crane Co., 749 F.3d 1117, 1121 (9th Cir. 2014). A 3 plaintiff therefore “bears the burden of establishing” standing, and he or she “must 4 clearly . . . allege facts demonstrating each element.” Spokeo, Inc. v. Robins, 136 S. 5 Ct. 1540, 1547 (2016) (internal quotation marks omitted, omission in original); Lujan 6 v. Defenders of Wildlife, 504 U.S. 555, 561 (1992). Additionally, a plaintiff must 7 establish standing for each claim and each form of relief sought in a pleading. See, 8 e.g., Town of Chester v. Laroe Estates, Inc., 137 S. Ct. 1645, 1650 (2017) (“standing 9 is not dispensed in gross” (internal quotation marks omitted)). To establish the 10 “irreducible constitutional minimum” of Article III standing, a plaintiff must have: 11 (1) suffered “an injury in fact,” (2) “that is fairly traceable to the challenged conduct” 12 of the defendant, and he or she must seek (3) “a remedy that is likely to redress that 13 injury” by a favorable court decision. Uzuegbunam v. Preczewski, 141 S. Ct. 792, 14 797 (2021) (citing Spokeo, Inc., 578 U.S. at 338). The injury must be “concrete and 15 particularized,” as well as “actual or imminent, not conjectural or hypothetical.” 16 Spokeo, 136 S. Ct. at 1548; see also Yazzie v. Hobbs, 977 F.3d 964, 966 (9th Cir. 17 2020) (plaintiff must show “a causal connection between the injury and the conduct 18 complained of”); Wash. Env’t Council v. Bellon, 732 F.3d 1131, 1141 (9th Cir. 2013) 19 (to satisfy the causality element for Article III standing, “[t]he line of causation 20 between the defendant’s action and the plaintiff’s harm must be more than 21 attenuated”). 22 Here, Plaintiff Rizzi is proceeding in this action as a pro se individual. A 23 plaintiff proceeding pro se in federal court, however, does not have standing to 24 vicariously assert the constitutional claims of others. This applies to a parent or 25 guardian attempting to raise a claim on behalf of a minor child. See Johns v. County 26 of San Diego, 114 F.3d 874, 876-77 (9th Cir. 1997) (“a parent or guardian cannot 27 bring an action on behalf of a minor child without retaining a lawyer”); United States 28 v. Mitchell, 915 F.2d 521, 526 n.8 (9th Cir. 1990) (pro se litigant does not have 1 standing to raise the claims of other persons whose rights may have been violated); 2 C.E. Pope Equity Trust v. United States, 818 F.2d 696, 697 (9th Cir. 1987) (a non- 3 attorney may appear pro se on his own behalf, but he or she “has no authority to 4 appear as an attorney for others”); see also Local Rule 83-2.2.1 (“Any person 5 representing himself or herself in a case without an attorney must appear pro se for 6 such purpose. That representation may not be delegated to any other person -- even 7 a spouse, relative, or co-party in the case. A non-attorney guardian for a minor or 8 incompetent person must be represented by counsel.”). Accordingly, Rizzi may not 9 raise any claims in this action based on alleged injuries to her minor child without 10 the representation of counsel. See, e.g., Cal. v. K.W., 2021 WL 2258717 at *2 (E.D. 11 Cal.

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Bluebook (online)
J.R. v. Palos Verdes Peninsula Unified School District, Board of Education, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jr-v-palos-verdes-peninsula-unified-school-district-board-of-education-cacd-2021.