(PS) Chamberlain v. Federal Election Commission

CourtDistrict Court, E.D. California
DecidedApril 28, 2025
Docket2:24-cv-00966
StatusUnknown

This text of (PS) Chamberlain v. Federal Election Commission ((PS) Chamberlain v. Federal Election Commission) 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) Chamberlain v. Federal Election Commission, (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 WILLIAM CHAMBERLAIN, No. 2:24-cv-00966-DAD-CKD (PS) 12 Plaintiffs, 13 v. ORDER AND FINDINGS AND 14 RECOMMENDATIONS DISMISSING FEDERAL ELECTION COMMISSION, PLAINTIFF’S FIRST AMENDED 15 COMPLAINT Defendant. 16

17 18 Plaintiff, William Chamberlain, proceeds without counsel and has filed a first amended 19 complaint (“FAC”) which is before the court for screening.1 The amended complaint fails to 20 establish the court’s jurisdiction and fails to state a claim. The amended complaint should be 21 dismissed without leave to amend for lack of subject matter jurisdiction and for failure to state a 22 claim. 23 I. SCREENING REQUIREMENT 24 Pursuant to 28 U.S.C. § 1915(e), the court must screen every in forma pauperis 25 proceeding, and must order dismissal of the case if it is “frivolous or malicious,” “fails to state a 26 claim on which relief may be granted,” or “seeks monetary relief against a defendant who is 27 1 Because plaintiff proceeds without counsel, this action is referred to the undersigned by Local 28 Rule 302(c)(21) pursuant to 28 U.S.C. § 636. 1 immune from such relief.” 28 U.S.C. § 1915(e)(2)(B); Lopez v. Smith, 203 F.3d 1122, 1126-27 2 (2000). In performing this screening, the court liberally construes a pro se plaintiff’s pleadings. 3 See Eldridge v. Block, 832 F.2d 1132, 1137 (9th Cir. 1987). 4 A complaint must contain “a short and plain statement of the claim showing that the 5 pleader is entitled to relief . . . .” Fed. R. Civ. P. 8(a)(2). Detailed factual allegations are not 6 required, but “[t]hreadbare recitals of the elements of a cause of action, supported by mere 7 conclusory statements, do not suffice[.]” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Bell 8 Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007)). While factual allegations are accepted as 9 true, legal conclusions are not. Iqbal, 556 U.S. at 678. Courts “are not required to indulge 10 unwarranted inferences[.]” Doe I v. Wal-Mart Stores, Inc., 572 F.3d 677, 681 (9th Cir. 2009) 11 (internal quotation marks and citation omitted). 12 Pro se litigants are entitled to have their pleadings liberally construed and to have any 13 doubt resolved in their favor. Eldridge, 832 F.2d at 1137. Nevertheless, to survive screening, a 14 plaintiff’s claims must be facially plausible, which requires sufficient factual detail to allow the 15 court to reasonably infer that a named defendant is liable for the misconduct alleged. Iqbal, 556 16 U.S. at 678. 17 II. PLAINTIFF’S ALLEGATIONS 18 Plaintiff brings this action against the Federal Election Commission (“FEC”). (ECF No. 19 9.) Plaintiff seeks judicial review under 52 U.S.C. § 30109(a)(8) of the FEC’s alleged failure to 20 act on an administrative complaint plaintiff filed against Chase Manhattan Bank and Donald 21 Trump for alleged violations of the Bipartisan Campaign Reform Act. (Id. at 1.) Plaintiff states 22 the administrative complaint was filed on October 6, 2020 and verbally dismissed by the FEC in 23 March 2022, over 120 days after the complaint was filed. (Id. at ¶ 3.) According to plaintiff, the 24 FEC did not investigate or formally respond to the complaint within 120 days as required, and did 25 not provide a written confirmation of dismissal or publish the complaint in a public forum. (Id. at 26 ¶¶ 5-6.) Plaintiff alleges that the FEC’s failure to act violated his rights under the First and 27 Fourteenth Amendments. (Id. at ¶¶ 8-14.) Plaintiff also alleges that the FEC’s failure to act 28 1 resulted in financial harm to Plaintiff, including lost political donations and a missed opportunity 2 to run in the 2024 election, totaling $99 million. (Id. at ¶ 7.) 3 III. DISCUSSION 4 Plaintiff’s original complaint was dismissed because it failed to state a claim upon which 5 relief can be granted. Plaintiff filed a FAC, however, the FAC does not establish the court’s 6 jurisdiction and fails to state a claim. 7 A. Subject Matter Jurisdiction 8 Federal courts are courts of limited jurisdiction. Kokkonen v. Guardian Life Insurance Co. 9 Of America, 511 U.S. 375, 377 (1994). In general, federal courts hear cases that arise in diversity 10 or present a federal question. See U.S. CONST. art. III §§ 1–2; 28 U.S.C. §§ 1331-32. 11 The presumption is against jurisdiction and “the burden of establishing the contrary rests 12 upon the party asserting jurisdiction.” Vacek v. U.S. Postal Serv., 447 F.3d 1248, 1250 (9th Cir. 13 2006) (citing Kokkonen, 511 U.S. at 377). “If the court determines at any time that it lacks 14 subject-matter jurisdiction, the court must dismiss the action.” Fed. R. Civ. P. 12(h)(3); see 15 Franklin v. State of Or., State Welfare Div., 662 F.2d 1337, 1342 (9th Cir. 1981) (court may 16 dismiss an action sua sponte for lack of jurisdiction). 17 Plaintiff has not established federal question jurisdiction. See 28 U.S.C. § 1331 (the 18 federal district courts have original jurisdiction over “all civil actions arising under the 19 Constitution, laws, or treaties of the United States.”). First, plaintiff claims that the FEC failed to 20 act on or investigate his administrative claim under 52 U.S.C. § 30109(a)(8). Exclusive 21 jurisdiction for this claim is vested in the United States District Court for the District of 22 Columbia. 52 U.S.C. § 30109(a)(8); see Salo v. Fed. Election Com’n, 2007 WL 1757352, at *1 23 (E.D. Cal. June 18, 2007) (citing an old version of the statute); Beverly v. Fed. Elections Com’n, 24 2009 WL 196361, at *1 (E.D. Cal. Jan. 28, 2009) (same). Plaintiff has improperly brought this 25 claim in the Eastern District of California. 26 Second, plaintiff’s claims under the First and Fourteenth Amendment must also fail. 27 “Absent a waiver, sovereign immunity shields the Federal Government and its agencies from 28 suit.” F.D.I.C. v. Meyer, 510 U.S. 471, 475 (1994). Plaintiff has not pled that there is a waiver of 1 sovereign immunity. See Salo, 2007 WL 1757352, at *1 (citing United States v. Mitchell, 463 2 U.S. 206, 212 (1983); F.D.I.C. v.

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Bluebook (online)
(PS) Chamberlain v. Federal Election Commission, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-chamberlain-v-federal-election-commission-caed-2025.