Megatel Homes LLC v. City of Mansfield, Texas

CourtDistrict Court, N.D. Texas
DecidedAugust 6, 2025
Docket3:24-cv-02295
StatusUnknown

This text of Megatel Homes LLC v. City of Mansfield, Texas (Megatel Homes LLC v. City of Mansfield, Texas) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Megatel Homes LLC v. City of Mansfield, Texas, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION MEGATEL HOMES, LLC and § CIPRIANI ISLAND LAGUNA § AZURE LLC, § § Plaintiffs, § § V. § No. 3:24-cv-2295-L § CITY OF MANSFIELD, TEXAS, § § Defendant. §

FINDINGS, CONCLUSIONS, AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE Defendant City of Mansfield, Texas moved to dismiss Plaintiffs Megatel Homes, LLC and Cipriani Island Laguna Azure LLC’s complaint under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). See Dkt. No. 7. Under 28 U.S.C. § 636(b), United States District Judge Sam A. Lindsay referred the City’s motion to dismiss to the undersigned United States magistrate judge for hearing, if necessary, and to submit proposed findings and recommendations as to its disposition. See Dkt. No. 8. Plaintiffs responded, and the City replied. See Dkt. Nos. 9, 12, & 13. For the reasons and to the extent set out below, the undersigned recommends that the Court grant the motion in part and deny it in part. Discussion Related to their efforts to develop land in Johnson County, Texas, Plaintiffs brings claims against the City under Sections 1 and 2 of the Sherman Act, 15 U.S.C. §§ 1 & 1px solid var(--green-border)">2, and Texas law, for the City’s alleged “tortious interference with Plaintiffs’ rights to obtain retail water utility services from Johnson County Special Utility District (‘JCSUD’) and other actionable misrepresentations,” Dkt. No. 1, ¶ 1.

According to Plaintiffs, “Defendant took these actions to prevent Plaintiffs from developing their property, by denying Plaintiffs’ access to water utility services unless Plaintiffs acquiesced to Mansfield’s unlawful demands for financial benefits that it has no right to impose.” Id. The City moves to dismiss this lawsuit for lack of subject-matter jurisdiction under Rule 12(b)(1), arguing primarily that Plaintiffs’ claims are not ripe, so they lack Article III standing.

And, if the Court disagrees and finds that it does have subject-matter jurisdiction over this lawsuit, the City moves to dismiss Plaintiffs’ claims under Rule 12(b)(6) because 1) the antitrust claims falter due to the state-action immunity doctrine and their not being compatible with what is essentially a contract dispute and 2) the state law intentional tort claims are barred by immunity. The City also argues that, if the Court finds that the federal law causes of

action should be dismissed, the Court should decline supplemental jurisdiction over the remaining claims. I. The Court should deny the City’s Rule 12(b)(1) request to dismiss for lack of subject-matter jurisdiction. Plaintiffs invoke the Court’s subject-matter jurisdiction under 28 U.S.C. § 1331 based on the presence of the Sherman Act counts. And Section 1331, as an “independent basis of subject matter jurisdiction” allows for supplemental jurisdiction under 28 U.S.C. § 1367 for the state law claims. Atkins v. Propst, No. 22-10609, 2023 WL 2658852, at *2 (5th Cir. Mar. 28, 2023) (per curiam) (citing Arena v. Graybar Elec. Co., Inc., 669 F.3d 214 (5th Cir. 2012)).

But, where that basis for subject matter jurisdiction drops out, a court may choose to decline to exercise supplemental jurisdiction over the remaining state law claims. See 28 U.S.C. § 1367(c); Carnegie-Mellon Univ. v. Cohill, 484 U.S. 343, 350 (1988); Enochs v. Lampasas Cnty., 641 F.3d 155, 158-59 (5th Cir. 2011). Likewise, “declaratory relief under [28 U.S.C.] § 2201 is appropriate only when there exists an independent basis for jurisdiction.” Parham v. Clinton, 374 F. App’x 503, 504 (5th Cir. 2010) (per curiam) (citing Simi Inv. Co. v. Harris Cnty., Tex., 236

F.3d 240, 247 (5th Cir. 2000) (“Declaratory Judgment Act claims, without another basis for jurisdiction, cannot support the district court’s jurisdiction.” (citation omitted))). Subject-matter jurisdiction under Section 1331 typically “exists when ‘a well- pleaded complaint establishes either that federal law creates the cause of action or that the plaintiff’s right to relief necessarily depends on resolution of a substantial

question of federal law.’” Borden v. Allstate Ins. Co., 589 F.3d 168, 172 (5th Cir. 2009) (quoting Franchise Tax Bd. v. Constr. Laborers Vacation Tr., 463 U.S. 1, 27-28 (1983)); see also In re Hot-Hed Inc., 477 F.3d 320, 323 (5th Cir. 2007) (“A federal question exists ‘if there appears on the face of the complaint some substantial, disputed question of federal law.’” (quoting Carpenter v. Wichita Falls Indep. Sch. Dist., 44 F.3d 362, 366 (5th Cir. 1995))). And, under Section 1331, “when a federal claim appears on the face of the complaint, dismissal for lack of subject matter jurisdiction is only proper in the case of a frivolous or insubstantial claim, i.e., a claim which has no plausible foundation

or which is clearly foreclosed by a prior [United States] Supreme Court decision.” Copeland v. E*Trade Cap. Mgmt., L.L.C., No. 24-10658, 2025 WL 66732, at *2 (5th Cir. Jan. 10, 2025) (per curiam) (cleaned up; quoting Young v. Hosemann, 598 F.3d 184, 188 (5th Cir. 2010) (quoting Bell v. Health-Mor, Inc., 549 F.2d 342, 344 (5th Cir. 1977))). “But compliance with § 1331 is necessary but not sufficient for federal subject matter jurisdiction.” Lutostanski v. Brown, 88 F.4th 582, 588 (5th Cir. 2023). That is

because “plaintiffs must also show that they have Article III standing.” Id. (citing Steel Co. v. Citizens for Better Env’t, 523 U.S. 83, 103-04 (1998)). So, if “plaintiffs lack standing, the district court lacks subject matter jurisdiction.” Id. As such, “[t]he doctrine of standing is an essential and unchanging part of the case-or-controversy requirement of Article III.” Hopkins v. Hosemann, 76 F.4th 378, 392 (5th Cir. 2023) (cleaned up).

To obtain “Article III standing, a plaintiff must allege that it has been injured, that the defendant caused the injury, and that the requested relief will redress the injury.” Cotton v. Certain Underwriters at Lloyd’s of London, 831 F.3d 592, 595 (5th Cir. 2016) (citing Lujan v. Defs. of Wildlife, 504 U.S. 555, 560-61 (1992)). So “[t]he question of standing is fundamentally about the propriety of an individual to litigate a claim irrespective of its legal merits.” West v. City of Santa Fe, Tex., No. 3:16-CV-0309, 2018 WL 4047115, at *11 (S.D. Tex. Aug. 16, 2018) (citing Warth v. Seldin, 422 U.S. 490, 498 (1975)), rec. adopted, 2018 WL 5276264 (S.D. Tex. Sept. 19, 2018).

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Bluebook (online)
Megatel Homes LLC v. City of Mansfield, Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/megatel-homes-llc-v-city-of-mansfield-texas-txnd-2025.