(PS) Brown v. Preferred Employers Ins.

CourtDistrict Court, E.D. California
DecidedJune 24, 2025
Docket2:25-cv-00627
StatusUnknown

This text of (PS) Brown v. Preferred Employers Ins. ((PS) Brown v. Preferred Employers Ins.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
(PS) Brown v. Preferred Employers Ins., (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 TAHTIANA JADE BROWN, No. 2:25-cv-0627-DC-CKD (PS) 12 Plaintiff, 13 v. FINDINGS AND RECOMMENDATIONS 14 PREFERRED EMPLOYERS INSURANCE, et al. 15 Defendants. 16 17 Plaintiff Tahtiana Brown1 proceeds without counsel on complaint filed on February 24, 18 2025, against defendants Preferred Employers Insurance, Berkeley Technology, and Dan Moon. 19 (ECF No. 1.) Counsel has appeared on behalf of the defendants, who have not filed any response 20 to the complaint.2 On June 9, 2025, plaintiff filed a motion for leave to amend the complaint 21 along with a proposed amended complaint. (ECF Nos. 14, 15.) Having reviewed the complaint 22 and proposed amended complaint, the undersigned finds plaintiff’s retaliation and racial 23 discrimination claims are duplicative of claims in an earlier-filed pending action. The court lacks 24 federal question jurisdiction over the remainder of the dispute. Thus, the undersigned will 25

1 Because plaintiff proceeds pro se, this matter is before the undersigned pursuant to 28 U.S.C. § 26 636(b)(1) and Local Rule 302(c)(21). 27 2 The record currently before the court does not indicate the defendants were properly served 28 under Rule 4 of the Federal Rules of Civil Procedure. 1 recommend dismissal of this action. 2 Federal courts are courts of limited jurisdiction. Kokkonen v. Guardian Life Insurance Co. 3 Of America, 511 U.S. 375, 377 (1994). In general, federal courts hear cases that arise in diversity 4 of citizenship3 or present a federal question. See U.S. CONST. art. III §§ 1–2; 28 U.S.C. §§ 1331- 5 32. Courts are required sua sponte to examine jurisdictional issues. Molski v. Arby's Huntington 6 Beach, 359 F. Supp. 2d 938, 943 (C.D. Cal. 2005) (citing B.C. v. Plumas Unified School District, 7 192 F.3d 1260, 1264 (9th Cir. 1999).) The presumption is against jurisdiction and “the burden of 8 establishing the contrary rests upon the party asserting jurisdiction.” Vacek v. U.S. Postal Serv., 9 447 F.3d 1248, 1250 (9th Cir. 2006) (citing Kokkonen, 511 U.S. at 377). “If the court determines 10 at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.” Fed. R. 11 Civ. P. 12(h)(3). It may do so sua sponte. Franklin v. State of Or., State Welfare Div., 662 F.2d 12 1337, 1342 (9th Cir. 1981). 13 Plaintiff’s complaint asserts the following four claims: (1) Bad Faith Conduct in Handling 14 Plaintiff’s Workers’ Compensation Claim; (2) Privacy Violations & Improper Access to Medical 15 Records; (3) QME Panel Request Manipulation & Procedural Violations; and (4) Retaliation & 16 Racial Discrimination (Title VII & FEHA). (ECF No. 1 at 5.) The proposed amended complaint 17 that accompanies plaintiff’s motion for leave to amend asserts the following five claims: (1) Bad 18 Faith Insurance Practices; (2) Negligence; (3) Privacy Violations; (4) Retaliation; and (5) 19 Procedural Due Process Violations. (ECF No. 15 at 2-3.) The asserted basis for jurisdiction is 20 federal question jurisdiction under 28 U.S.C. §1331 and supplemental jurisdiction for state law 21 claims under 28 U.S.C. § 1367. However, the case does not present a federal question. 22 Federal district courts have original jurisdiction over “all civil actions arising under the 23 Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331. “A case ‘arises under’ 24 federal law either where federal law creates the cause of action or ‘where the vindication of a 25 right under state law necessarily turn[s] on some construction of federal law.’” Republican Party 26 of Guam v. Gutierrez, 277 F.3d 1086, 1088-89 (9th Cir. 2002) (citing Franchise Tax Bd. v. 27 3 Plaintiff does not allege that diversity jurisdiction exists under 28 U.S.C. § 1332 and the 28 complaint contains no such indication. 1 Constr. Laborers Vacation Trust, 463 U.S. 1, 8-9 (1983)). A federal question exists if: (1) federal 2 law creates the cause of action, or (2) a substantial question of federal law is a necessary element 3 of a plaintiff’s well-pleaded complaint. See Coeur d’Alene Tribe v. Hawks, 933 F.3d 1052, 1055 4 (9th Cir. 2019); Caterpillar Inc. v. Williams, 482 U.S. 386, 392 (1987) (under the well-pleaded 5 complaint rule, “federal jurisdiction exists only when a federal question is presented on the face 6 of the plaintiff’s properly pleaded complaint”). 7 Plaintiff’s claims for bad faith insurance practices, negligence based on “mishandling 8 Plaintiff’s sensitive records,” and “QME Panel Request Manipulation & Procedural Violations”4 9 do not arise “under the Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331; see 10 also Agullard v. Principal Life Ins. Co., 685 F. Supp. 2d 947, 953 (D. Ariz. 2010) (breach of 11 contract and bad faith insurance claims “provide no basis for federal question jurisdiction”); 12 Friedmann v. Berkshire Hathaway Grp., No. C25-5070JLR, 2025 WL 896812, at *4 (W.D. Wash. 13 Mar. 24, 2025) (dismissing bad faith insurance claims for lack of subject matter jurisdiction); 14 Polus v. Sharp Healthcare, No. 320CV02253RBMKSC, 2022 WL 1478516, at *2 (S.D. Cal. May 15 9, 2022) (no federal-question jurisdiction over state-law negligence claim). 16 In addition, HIPAA creates no private cause of action. United States v. Streich, 560 F.3d 17 926, 935 (9th Cir. 2009) (“HIPAA does not provide any private right of action”). Thus, plaintiff’s 18 claims asserting privacy violations, including under HIPAA, and improper access to medical 19 records do not present a substantial question of federal law. See In re Anthem, Inc., 129 F. Supp. 20 3d 887, 897-98 (N.D. Cal. 2015) (citing Webb v. Smart Document Solutions, LLC, 499 F.3d 21 1078, 1082 (9th Cir. 2007). 22 Plaintiff’s claims asserting procedural due process violations by these defendants do not 23 present a substantial question of federal law because “only state action is subject to scrutiny under 24 the Due Process Clause.” Davis v. Prudential Securities, Inc., 59 F.3d 1186, 1190-1191 (11th Cir. 25 1995); Lugar v. Edmonson Oil Co., 457 U.S. 922

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Bluebook (online)
(PS) Brown v. Preferred Employers Ins., Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-brown-v-preferred-employers-ins-caed-2025.