Mayfield v. Thompson

CourtDistrict Court, S.D. Georgia
DecidedSeptember 17, 2024
Docket4:24-cv-00198
StatusUnknown

This text of Mayfield v. Thompson (Mayfield v. Thompson) is published on Counsel Stack Legal Research, covering District Court, S.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mayfield v. Thompson, (S.D. Ga. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION JOYCE ANN MAYFIELD, ) ) Plaintiff, ) ) v. ) CV424-198 ) BRUCE THOMPSON, ) Commissioner, Georgia ) Department of Labor, ) ) Defendant. ) ORDER AND REPORT AND RECOMMENDATION Pro se plaintiff Joyce Ann Mayfield has filed this action challenging a determination by the Georgia Department of Labor that she was ineligible for unemployment benefits. See doc. 1 at 6-7. She moves to proceed in forma pauperis. Doc. 2. Her original Motion was unsigned, see doc. 4, but she has corrected the defect, doc. 6. Because it appears that she lacks sufficient funds to pay the required filing fee, her Motion is GRANTED. Doc. 2. The Court, therefore, proceeds to screen her Complaint. See 28 U.S.C. § 1915(e)(2). Failure to state a claim under § 1915(e)(2)(B)(ii) is governed by the same standard as dismissal for failure to state a claim under [Federal Rule of Civil Procedure] 12(b)(6).” Wilkerson v. H & S, Inc., 366 F. App'x 49, 51 (11th Cir. 2010) (citing Mitchell v. Farcass, 112 F.3d 1483, 1490

(11th Cir. 1997)). To avoid dismissal, plaintiff’s pleadings must “state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). “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.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). The pleadings cannot rest merely on an “unadorned, the-defendant-unlawfully-harmed- me accusation,” id. at 678, and the facts offered in support of the claims

must rise to a level greater than mere speculation, Twombly, 550 U.S. at 555. Stated otherwise, the complaint must provide a “‘plain statement’ possess[ing] enough heft to ‘sho[w] that the pleader is entitled to relief.’”

Id. at 557 (quoting Fed. R. Civ. P. 8(a)(2)). Mayfield alleges that the Georgia Department of Labor determined that she was ineligible for unemployment benefits in September 2023.

Doc. 1 at 6. Although the exact procedure that led to that conclusion is not entirely clear, it appears from her Complaint that the claim was denied based on her failure to respond to the Department’s request for additional information. Id. at 6-7. Although the Complaint references that the termination which led Mayfield to seek unemployment benefits

may have been related to a dispute over absences perhaps excused by the federal Family and Medical Leave Act (“FMLA”), 29 U.S.C. §§ 2611, et seq., doc. 1 at 6, she does not identify any statutory basis for this Court’s

jurisdiction, id. at 3. “Federal courts are courts of limited jurisdiction,” Kokkonen v.

Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994), and “[i]f the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.” Fed. R. Civ. P. 12(h)(3). This Court has an

“independent obligation to ensure that jurisdiction exists.” Morrison v. Allstate Indem. Co., 228 F.3d 1255, 1275 (11th Cir. 2000). Plaintiff bears the burden of pleading the grounds on which the Court might assert

jurisdiction over the asserted claims. Fed. R. Civ. P. 8(a)(1); see also, e.g., Underwriters at Lloyd’s, London v. Osting-Schwinn, 613 F.3d 1079, 1085 (11th Cir. 2010) (“The party commencing suit in federal court . . . has the

burden of establishing, by a preponderance of the evidence, facts supporting the existence of federal jurisdiction.”); Beavers v. A.O. Smith Elec. Prods. Co., 265 F. App’x 772, 777 (11th Cir. 2008) (“The plaintiff[ ], as the party asserting diversity jurisdiction, [has] the burden to ‘affirmatively allege facts demonstrating the existence of jurisdiction.’”

(quoting Taylor v. Appleton, 30 F.3d 1365, 1367 (11th Cir. 1994))). The Court’s jurisdiction can be established either because the complaint presents a federal question, 28 U.S.C. § 1331, or by the

diversity of the parties, 28 U.S.C. § 1332. There is no plausible basis for this Court’s diversity jurisdiction. Plaintiff, a Georgia citizen, see doc. 1

at 1, has sued the Commissioner of the Georgia Department of Labor, id. at 2. Federal question jurisdiction exists if a civil action arises “under the Constitution, laws, or treaties of the United States.” 28 U.S.C.

§ 1331. When examining assertions of federal question jurisdiction, the Court must rely upon the well-pleaded complaint. Adventure Outdoors, Inc. v. Bloomberg, 552 F.3d 1290, 1295 (11th Cir. 2008) (citing Louisville

& Nashville R. Co. v. Mottley, 211 U.S. 149 (1908)). As this Court has explained, the “mere mention of certain federal statutes [does] not establish subject matter jurisdiction.” McLemore v. Henry, 2020 WL

1848053, at *1 (S.D. Ga. Apr. 13, 2020) (citations omitted). Plaintiff’s dispute over the validity of the Department’s determination of her entitlement to state unemployment benefits does not plausibly implicate any federal constitutional or statutory claim. See, e.g., doc. 1 at 3; Reid v. Georgia Dept. of Labor Career Ctr., 2017 WL 1949222, at *2 (M.D. Ga.

May 10, 2017) (citing, inter alia., Thornton v. Albany Drivers License, 2012 WL 3191769, at *2 (M.D. Ga. Aug. 2, 2012)) (denial of state unemployment benefits does not raise a federal question sufficient to

establish subject matter jurisdiction). Moreover, even if there were some plausible basis for this Court’s

subject matter jurisdiction, a suit against the Commissioner in his official capacity1 would be barred by the Eleventh Amendment. The Eleventh Amendment precludes suits against “arms of the state” in federal court,

unless the immunity is abrogated by Congress or waived by the state being sued. See, e.g., Manders v. Lee, 338 F.3d 1304, 1308 (11th Cir. 2003). Determination of whether a particular agency is an “arm of the

state,” entitled to Eleventh Amendment immunity, requires application of a four-factor test. See id. at 1309. Courts have recognized that the

1 “[O]fficial-capacity claims against an officer are simply another way of pleading an action against an entity of which an officer is an agent.” Gurrera v. Palm Beach Cnty. Sheriff’s Office, 657 F. App’x 886, 892 (11th Cir. 2016) (internal citation and quotations omitted).

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Related

Mitchell v. Farcass
112 F.3d 1483 (Eleventh Circuit, 1997)
Willie Santonio Manders v. Thurman Lee
338 F.3d 1304 (Eleventh Circuit, 2003)
Adventure Outdoors, Inc. v. Michael Bloomberg
552 F.3d 1290 (Eleventh Circuit, 2008)
Louisville & Nashville Railroad v. Mottley
211 U.S. 149 (Supreme Court, 1908)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Underwriters at Lloyd's, London v. Osting-Schwinn
613 F.3d 1079 (Eleventh Circuit, 2010)
Vincent Vidal Mitchell v. United States
612 F. App'x 542 (Eleventh Circuit, 2015)
Adrian Jenkins v. Susan M. Walker
620 F. App'x 709 (Eleventh Circuit, 2015)
Carol Wilkerson v. H&S, Inc.
366 F. App'x 49 (Eleventh Circuit, 2010)
Maurice Symonette v. V.A. Leasing Corporation
648 F. App'x 787 (Eleventh Circuit, 2016)
Vincenzo Gurrera v. Palm Beach County Sheriff's Office
657 F. App'x 886 (Eleventh Circuit, 2016)
Taylor v. Appleton
30 F.3d 1365 (Eleventh Circuit, 1994)
Beavers v. A.O. Smith Electrical Products Co.
265 F. App'x 772 (Eleventh Circuit, 2008)

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Mayfield v. Thompson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mayfield-v-thompson-gasd-2024.