Moses v. City of Memphis

CourtDistrict Court, W.D. Tennessee
DecidedFebruary 8, 2024
Docket2:23-cv-02627
StatusUnknown

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

Bluebook
Moses v. City of Memphis, (W.D. Tenn. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE AT MEMPHIS ______________________________________________________________________________

CITY OF MEMPHIS, ) ) Plaintiff, ) ) v. ) Case No. 2:23-cv-02627-JTF-atc ) 2383 Jackson Avenue, Memphis, ) Shelby County, Tennessee 38108 ) Parcel ID 052013 00003, ) ) Defendant, ) ) PAMELA MOSES, ) HOLLYWOOD COMMUNITY ) NEIGHBORHOOD ASSOCIATION, ) RISE UP AMERICA, ) ) Claimants. )

ORDER OF REMAND

On February 10, 2022, the City of Memphis (“City”) initiated an action in the Environmental Court of Shelby County, Tennessee for the Thirtieth Judicial District against the property identified as parcel 052013 00003 in the Register’s office of Shelby County Tennessee and municipally known as 2383 Jackson Avenue, Memphis, Tennessee 38108. (ECF No. 1, 1-3, 5.) The owner of the subject property is Pinnacle Pentecostal Holiness Church Inc. (Id.) On October 2, 2023, pro se intervenors Pamela Moses, the Hollywood Community Neighborhood Association, (“HCNA”), and Rise up America (“RUA”), identifying themselves as “defendant/interested equitable party and a party” filed a notice of removal with this Court. (Id. at 1.) Intervenors allege that this Court has subject matter jurisdiction over this action because the case presents a federal question. (Id.) For the reasons set forth below, the Court REMANDS this action. I. ANALYSIS A. Subject Matter Jurisdiction

District courts “have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331. Federal courts have a duty to consider subject matter jurisdiction in every case. Thus, courts may raise the issue of subject matter jurisdiction sua sponte. See Answers in Genesis of Kentucky, Inc. v. Creation Ministries Int'l, Ltd., 556 F.3d 459, 465 (6th Cir. 2009) “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.” In re DePuy Orthopaedics, Inc. ASR Hip Implant Prod. Liab. Litig., 953 F.3d 890, 893–94 (6th Cir. 2020) (quoting Bender v. Williamsport Area Sch. Dist., 475 U.S. 534, 541 (1986)). “It is to be presumed that a cause lies outside this limited jurisdiction, and the burden of establishing the contrary rests upon the party asserting jurisdiction.” Kokkonen v.

Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994) (citations omitted). Federal question jurisdiction is proper when a federal question is presented on the face of plaintiff’s complaint. Chase Manhattan Mortg. Corp. v. Smith, 507 F.3d 910, 914 (6th Cir. 2007) (quoting Caterpillar, Inc. v. Williams, 482 U.S. 386, 392 (1987)). A defense that raises a federal question is inadequate to confer federal jurisdiction. Franchise Tax Bd. of State of Cal. v. Constr. Laborers Vacation Tr. for S. California, 463 U.S. 1, 10 (1983) (quoting Louisville & Nashville R. Co. v. Mottley, 211 U.S. 149, 152 (1908)). In this case, the City alleged that the subject property was out of compliance with the City’s Housing Code of Ordinances, and was therefore certified to be a public nuisance as that term is defined under the Tennessee Neighborhood Preservation Act, Tenn. Code Ann. § 13-6-102(12). (ECF No. 1-4, 1.) Moses, apparently intervening on behalf of herself and the two organizations HCNA and RUA, contends that this case raises a federal question. (ECF No. 1, 1.) She argues that the Environmental Court violated 42 U.S.C. § 1981 by subjecting her to disparate treatment and

retaliation based on gender, race, and disability. (Id.) She also states that this case concerns an intentional infliction of emotional distress claim arising under the Federal Tort Claims Act, Title 28 U.S.C. § 2671. (Id. at 1-2.) Moses asserts, without supporting facts, eight questions in her section entitled “Federal Questions Presented,” but aside from the eighth question which appears to just be a restatement of her discrimination claim, none of the questions presented are federal questions. (See id. at 3.) Furthermore, none of these alleged federal claims are presented on the face of plaintiff’s complaint, so they cannot confer federal jurisdiction over this environmental nuisance action. After review of the record, the Court finds that Moses’s assertion of claims pursuant to § 1981 and § 2671 fail to confer subject matter jurisdiction.

B. Removal A defendant may remove a case only if the claim could have been brought in federal court. 28 U.S.C. § 1441(a). Removal jurisdiction is determined from the “well-pleaded complaint.” Est. of Cornell v. Bayview Loan Servicing, LLC, 908 F.3d 1008, 1011 (6th Cir. 2018) (quoting Merrell Dow Pharm. Inc. v. Thompson, 478 U.S. 804, 808 (1986)). Defenses invoking federal law do not provide a basis for removal. See Miller v. Bruenger, 949 F.3d 986, 992 (6th Cir. 2020) (citing Caterpillar Inc. v. Williams, 482 U.S. 386, 399 (1987)). Because removal statutes encroach on state sovereignty, they are to be narrowly construed. See Long v. Bando Mfg. of Am., Inc., 201 F.3d 754, 757 (6th Cir. 2000) (citing Shamrock Oil & Gas Corp. v. Sheets, 313 U.S. 100, 108–09 (1941). Principles of comity and federalism dictate that removal jurisdiction should be exercised only when it is clearly established, and any ambiguity regarding the scope of the removal statutes should be resolved in favor of remand to state court. Brierly v. Alusuisse Flexible Packaging, Inc., 184 F.3d 527, 534 (6th Cir. 1999), cert. denied, 528

U.S. 1076 (2000). The removal statute provides that an action that is not initially removable may be removed within 30 days of the case becoming removable. See 28 U.S.C. § 1446(b).

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Moses v. City of Memphis, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moses-v-city-of-memphis-tnwd-2024.