(PS) Chamberlain v. Federal Election Commission

District Court, E.D. California·Decided April 28, 2025·No. 2:24-cv-00966·Unknown

Opinion

WILLIAM CHAMBERLAIN, No. 2:24-cv-00966-DAD-CKD (PS) Plaintiffs, v. ORDER AND FINDINGS AND RECOMMENDATIONS DISMISSING FEDERAL ELECTION COMMISSION, PLAINTIFF’S FIRST AMENDED Defendant.

Plaintiff, William Chamberlain, proceeds without counsel and has filed a first amended complaint (“FAC”) which is before the court for screening.1 The amended complaint fails to establish the court’s jurisdiction and fails to state a claim. The amended complaint should be dismissed without leave to amend for lack of subject matter jurisdiction and for failure to state a claim. Pursuant to 28 U.S.C. § 1915(e), the court must screen every in forma pauperis proceeding, and must order dismissal of the case if it is “frivolous or malicious,” “fails to state a claim on which relief may be granted,” or “seeks monetary relief against a defendant who is 1 Because plaintiff proceeds without counsel, this action is referred to the undersigned by Local Rule 302(c)(21) pursuant to 28 U.S.C. § 636. immune from such relief.” 28 U.S.C. § 1915(e)(2)(B); Lopez v. Smith, 203 F.3d 1122, 1126-27 (2000). In performing this screening, the court liberally construes a pro se plaintiff’s pleadings. See Eldridge v. Block, 832 F.2d 1132, 1137 (9th Cir. 1987). A complaint must contain “a short and plain statement of the claim showing that the pleader is entitled to relief . . . .” Fed. R. Civ. P. 8(a)(2). Detailed factual allegations are not required, but “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice[.]” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)). While factual allegations are accepted as true, legal conclusions are not. Iqbal, 556 U.S. at 678. Courts “are not required to indulge unwarranted inferences[.]” Doe I v. Wal-Mart Stores, Inc., 572 F.3d 677, 681 (9th Cir. 2009) (internal quotation marks and citation omitted). Pro se litigants are entitled to have their pleadings liberally construed and to have any doubt resolved in their favor. Eldridge, 832 F.2d at 1137. Nevertheless, to survive screening, a plaintiff’s claims must be facially plausible, which requires sufficient factual detail to allow the court to reasonably infer that a named defendant is liable for the misconduct alleged. Iqbal, 556 U.S. at 678. Plaintiff brings this action against the Federal Election Commission (“FEC”). (ECF No. 9.) Plaintiff seeks judicial review under 52 U.S.C. § 30109(a)(8) of the FEC’s alleged failure to act on an administrative complaint plaintiff filed against Chase Manhattan Bank and Donald Trump for alleged violations of the Bipartisan Campaign Reform Act. (Id. at 1.) Plaintiff states the administrative complaint was filed on October 6, 2020 and verbally dismissed by the FEC in March 2022, over 120 days after the complaint was filed. (Id. at ¶ 3.) According to plaintiff, the FEC did not investigate or formally respond to the complaint within 120 days as required, and did not provide a written confirmation of dismissal or publish the complaint in a public forum. (Id. at ¶¶ 5-6.) Plaintiff alleges that the FEC’s failure to act violated his rights under the First and Fourteenth Amendments. (Id. at ¶¶ 8-14.) Plaintiff also alleges that the FEC’s failure to act resulted in financial harm to Plaintiff, including lost political donations and a missed opportunity to run in the 2024 election, totaling $99 million. (Id. at ¶ 7.) Plaintiff’s original complaint was dismissed because it failed to state a claim upon which relief can be granted. Plaintiff filed a FAC, however, the FAC does not establish the court’s jurisdiction and fails to state a claim. A. Subject Matter Jurisdiction Federal courts are courts of limited jurisdiction. Kokkonen v. Guardian Life Insurance Co. Of America, 511 U.S. 375, 377 (1994). In general, federal courts hear cases that arise in diversity or present a federal question. See U.S. CONST. art. III §§ 1–2; 28 U.S.C. §§ 1331-32. The presumption is against jurisdiction and “the burden of establishing the contrary rests upon the party asserting jurisdiction.” Vacek v. U.S. Postal Serv., 447 F.3d 1248, 1250 (9th Cir. 2006) (citing Kokkonen, 511 U.S. at 377). “If 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); see Franklin v. State of Or., State Welfare Div., 662 F.2d 1337, 1342 (9th Cir. 1981) (court may dismiss an action sua sponte for lack of jurisdiction). Plaintiff has not established federal question jurisdiction. See 28 U.S.C. § 1331 (the federal district courts have original jurisdiction over “all civil actions arising under the Constitution, laws, or treaties of the United States.”). First, plaintiff claims that the FEC failed to act on or investigate his administrative claim under 52 U.S.C. § 30109(a)(8). Exclusive jurisdiction for this claim is vested in the United States District Court for the District of Columbia. 52 U.S.C. § 30109(a)(8); see Salo v. Fed. Election Com’n, 2007 WL 1757352, at *1 (E.D. Cal. June 18, 2007) (citing an old version of the statute); Beverly v. Fed. Elections Com’n, 2009 WL 196361, at *1 (E.D. Cal. Jan. 28, 2009) (same). Plaintiff has improperly brought this claim in the Eastern District of California. Second, plaintiff’s claims under the First and Fourteenth Amendment must also fail. “Absent a waiver, sovereign immunity shields the Federal Government and its agencies from suit.” F.D.I.C. v. Meyer, 510 U.S. 471, 475 (1994). Plaintiff has not pled that there is a waiver of sovereign immunity. See Salo, 2007 WL 1757352, at *1 (citing United States v. Mitchell, 463 U.S. 206, 212 (1983); F.D.I.C. v. Meyer, 510 U.S. 471, 475 (1994)). Further, federal agencies are not subject to liability under 42 U.S.C. § 1983. Jachetta v. United States, 653 F.3d 898, 908 (9th Cir. 2011); see Azul-Pacifico, Inc. v. City of Los Angeles,

(PS) Chamberlain v. Federal Election Commission, (E.D. Cal. 2025).

(PS) Chamberlain v. Federal Election Commission ((PS) Chamberlain v. Federal Election Commission) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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