Pete v. Small Business Administration

CourtDistrict Court, E.D. Texas
DecidedJuly 28, 2025
Docket1:25-cv-00223
StatusUnknown

This text of Pete v. Small Business Administration (Pete v. Small Business Administration) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pete v. Small Business Administration, (E.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS

DAVID R. PETE, § § Plaintiff, § § versus § § CIVIL ACTION NO. 1:25-CV-223-MAC SMALL BUSINESS § ADMINISTRATION and TREASURY § OFFSET DIVISION, § § Defendants. §

MEMORANDUM AND ORDER ADOPTING THE REPORT AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE

Pursuant to 28 U.S.C. § 636 and the Local Rules of Court for the Assignment of Duties to United States Magistrate Judges, the district court referred this proceeding to the undersigned magistrate judge to conduct all pretrial proceedings, to enter findings of fact and recommend disposition on case-dispositive matters, and to determine non-dispositive matters. See 28 U.S.C. § 636(b)(1); E.D. TEX. LOC. R. CV-72. On July 9, 2025, the magistrate judge issued a Report and Recommendation (#5) advising the court to: (1) dismiss the case without prejudice, sua sponte, because Plaintiff David R. Pete, proceeding pro se and in forma pauperis, failed to identify a valid waiver of federal sovereign immunity, thus depriving the court of subject matter jurisdiction; (2) deny Pete leave to amend his complaint because of this jurisdictional divesture; and (3) deny as moot Pete’s Proposed Entry of Default, an Affidavit in Support of Entry of Default, and a Motion for Default Judgment (#4). I. Plaintiff David R. Pete’s Objections (#6) to the Report and Recommendation (#5) are Overruled

On June 16, 2025, Pete filed timely objections (#6) to the Report and Recommendation (#5). A party who timely files specific, written objections to a magistrate judge’s report and recommendation is entitled to a de novo determination of findings or recommendations to which the party specifically objects. 28 U.S.C. § 636(b)(1)(C); FED. R. CIV. P. 72(b)(2)–(3). To be specific, an objection must identify the specific finding or recommendation to which objection is made, state the basis for the objection, and specify the place in the magistrate judge’s report and recommendation where the disputed determination is found. An objection that merely incorporates by reference or refers to the briefing before the magistrate judge is not specific. “Frivolous, conclusive or general objections need not be considered by the district court.” Nettles v. Wainwright, 677 F.2d 404, 410 n.8 (5th Cir. 1982) (en banc), overruled on other grounds by Douglass v. United Servs. Auto. Ass’n, 79 F.3d 1412 (5th Cir. 1996) (en banc). Pete specifically objects to each finding and recommendation in the report. See (#6.) A. Federal Sovereign Immunity and Subject Matter Jurisdiction Pete is trying to sue the Small Business Administration (“SBA”) and Treasury Offset

Division. See (#1.) The magistrate judge first found that Pete has not identified a valid waiver of sovereign immunity to hale the SBA, an executive branch agency, into court. (#5 at 5–6.) It was further determined that the Treasury Offset “Program,” incorrectly pleaded as the Treasury Offset “Division,” is not a jural entity, department, or executive constituent amenable to suit; rather, it is “the United States Department of Treasury’s … programmatic implementation authorized by the Debt Collection Improvement Act to collect debts owed to federal agencies.” (Id. at 5–7.) Even assuming that Pete intended to name the Treasury Department, or only the SBA, he failed to direct the court to a waiver of sovereign immunity. (Id. at 6–7.) Pete objects twofold. First, Pete argues that sovereign immunity is an affirmative defense and plaintiffs are not required to anticipate or plead around affirmative defenses; instead, it must be raised by

defendants. (#6 at 3–4.) Initially, none of the four out-of-circuit cases cited by Pete legally support this proposition. In fact, the court is unable to even locate three of the cases with the citations provided by Pete.1 If Pete is otherwise correct, then he forgets that the court possesses the inherent authority to raise matters of subject matter jurisdiction, including sovereign immunity, “at any time.” FED. R. CIV. P. 12(h)(3) (emphasis added); see Craft ex rel. Est. of Craft v. United Servs. Auto. Ass’n, No. 23-4074, 2024 WL 2891829, at *1 (E.D. La. June 10, 2024) (first citing Kontrick v. Ryan, 540 U.S. 443, 456 (2004); and then citing McDonal v. Abbott Labs., 408 F.3d 177, 182 n.5 (5th Cir. 2005)) (“The lack of subject-matter jurisdiction

may be raised at any time during pendency of the case by any party or by the court.”). More than that, “sua sponte dismissal is mandatory when a court discovers that it lacks subject-matter jurisdiction.” Carver v. Atwood, 18 F.4th 494, 497 (5th Cir. 2021) (first citing FED. R. CIV. P. 12(h)(3); and then citing Ex parte McCardle, 74 U.S. (7 Wall.) 506, 514 (1869)). Pete has not alerted the court to any case law displacing its sua sponte responsibility, mandated by Congress, to assure itself of subject matter jurisdiction. See (#6.) Pete’s first subsidiary objection is overruled.

1 These cases are: “Maddox v. Parole Comm’n, 187 F. Supp. 3d 1, 8-9 (D.D.C. 2016);” “Passmore v. The Pentagon, No. l:19-CV-200, 2020 WL 465337, at 5 (S.D. Ohio Jan. 17, 2020);” and “Butler v. United States, 702 F.2d 676, 678 (11th Cir. 1983).” (#6 at 3 (italics added).) The court managed to locate Passmore v. The Pentagon by using the civil action number on the CM/ECF system, but the court declines to hunt through the docket on Pete’s behalf. Pete objects next that he identified the following waivers of sovereign immunity: 5 U.S.C. § 702; 28 U.S.C. §§ 1331, 2671–80, 1346(a)(2), 1491(a)(1); and 31 U.S.C. §§ 3711 et seq. (#6 at 3.) The only statute identified in the complaint is 28 U.S.C. § 1331, which the magistrate judge correctly determined “is a general jurisdiction statute and does not provide a

general waiver of sovereign immunity.” (#5 at 6 (quoting Shanbaum v. United States, 32 F.3d 180, 182 (5th Cir. 1994) (citing Voluntary Purchasing Groups, Inc. v. Reilly, 889 F.2d 1380, 1385 (5th Cir. 1989)).) Pete’s references to the remaining statutes are not properly before the court. See Finley v. Johnson, 243 F.3d 215, 219 n.3 (5th Cir. 2001) (citing United States v. Armstrong, 951 F.2d 626, 630 (5th Cir. 1992)) (“We have held that issues raised for the first time in objections to the report of a magistrate judge are not properly before the district judge.”); Paulson v. TDCJ, No. 6:22-CV-2-JDK-KNM, 2024 WL 4346376, at *4 (E.D. Tex. Sept. 27, 2024); Traylor v. United States, No.

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Related

Shanbaum v. United States
32 F.3d 180 (Fifth Circuit, 1994)
New York Life Insurance v. Brown
84 F.3d 137 (Fifth Circuit, 1996)
Finley v. Johnson
243 F.3d 215 (Fifth Circuit, 2001)
McDonal Ex Rel. McDonal v. Abbott Laboratories
408 F.3d 177 (Fifth Circuit, 2005)
Ex Parte McCardle
74 U.S. 506 (Supreme Court, 1869)
Kontrick v. Ryan
540 U.S. 443 (Supreme Court, 2004)
United States v. Connie C. Armstrong
951 F.2d 626 (Fifth Circuit, 1992)
United States v. Jimmy D. McGuire
79 F.3d 1396 (Fifth Circuit, 1996)
Dl v. District of Columbia
187 F. Supp. 3d 1 (District of Columbia, 2016)
Carver v. Atwood
18 F.4th 494 (Fifth Circuit, 2021)
Jackson v. Roosevelt Federal Savings & Loan Ass'n
702 F.2d 674 (Eighth Circuit, 1983)

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Pete v. Small Business Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pete-v-small-business-administration-txed-2025.