Pugh v. Autauga

CourtDistrict Court, M.D. Alabama
DecidedAugust 12, 2025
Docket2:25-cv-00525
StatusUnknown

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

Bluebook
Pugh v. Autauga, (M.D. Ala. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

DEVIN PUGH, ) ) Plaintiff, ) ) v. ) CASE NO. 2:25-CV-525-RAH-KFP ) AUTAUGA COUNTY, et al., ) ) Defendants. )

RECOMMENDATION OF THE MAGISTRATE JUDGE Pro se Plaintiff Devin Brandis Pugh filed this suit against 23 different counties in the state of Alabama on July 16, 2025. Doc. 1. Upon review of the Complaint, the undersigned recommends that the case be dismissed for lack of subject matter jurisdiction. I. LEGAL STANDARD Federal courts have limited jurisdiction and possess only the power authorized by a statute or the Constitution. Kokkonen v. Guardian Life Ins. of Am., 511 U.S. 375, 377 (1994). Courts should presume that a case lies outside this limited jurisdiction, and the burden of establishing the contrary is on the party asserting jurisdiction. Id. A federal district court must have at least one of the three types of federal subject matter jurisdiction: “(1) jurisdiction under a specific statutory grant; (2) federal question jurisdiction pursuant to 28 U.S.C. § 1331; or (3) diversity jurisdiction pursuant to 28 U.S.C. § 1332(a).” Baltin v. Alaron Trading Corp., 128 F.3d 1466, 1469 (11th Cir. 1997); see also 28 U.S.C. §§ 1331, 1332. For purposes of federal question jurisdiction, “a case ‘arises under’ federal law if the plaintiffs plead a cause of action created by federal law or if a substantial disputed area of federal law is a necessary element of a state-law claim.” McKinnes v. Am. Int’l Grp., Inc., 420 F. Supp. 2d 1254, 1259 (M.D. Ala. 2006) (citing Franchise Tax Bd. v. Constr. Laborers

Vacation Tr., 463 U.S. 1, 9–10, 13 (1983)). For diversity jurisdiction, the amount in controversy must exceed $75,000 and the action must be between citizens of different states. 28 U.S.C. § 1332(a). Pro se pleadings are held to a less stringent standard than those drafted by an attorney and should be liberally construed by courts. Tannenbaum v. United States, 148 F.3d 1262, 1263 (11th Cir. 1998); Haines v. Kerner, 404 U.S. 519, 520 (1972) (per curiam).

However, the leniency afforded pro se litigants does not allow the Court to “act as de facto counsel or rewrite an otherwise deficient pleading to sustain an action.” Bilal v. Geo Care, LLC, 981 F.3d 903, 911 (11th Cir. 2020). Pro se pleadings must still comply with the Federal Rules of Civil Procedure. Hopkins v. Saint Lucie Cnty. Sch. Bd., 399 F. App’x 563, 565 (11th Cir. 2010) (citing McNeil v. United States, 508 U.S. 106, 113 (1993)).

II. PLAINTIFF’S COMPLAINT Plaintiff’s handwritten Complaint states that Plaintiff is bringing this action against these 23 counties concerning “the lack of public transportation using buses with at least 50 stops in the above counties.” Doc. 1 at 1. Plaintiff claims this conduct violates “the 14th amendment of the Constitution of the United States by the lack of adequate transportation

deprives [sic] the states, therefore the counties liberation from the confinement [illegible] [illegible] etc . . . of their residencies.” Id. III. DISCUSSION The Complaint is due to be dismissed for lack of subject matter jurisdiction because

Plaintiff has not asserted facts that show the existence of federal jurisdiction. A federal court “should inquire into whether it has subject matter jurisdiction at the earliest possible stage in the proceedings. Indeed, it is well settled that a federal court is obligated to inquire into subject matter jurisdiction sua sponte whenever it may be lacking.” Univ. of S. Ala. v. Am. Tobacco Co., 168 F.3d 405, 410 (11th Cir. 1999). “When a plaintiff sues in federal court, she must affirmatively allege facts that, taken as true, show the existence of federal

subject matter jurisdiction.” McQueary v. Child Support Enf’t, 812 F. App’x 911, 913 (11th Cir. 2020). “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) (internal citations omitted). “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). “Federal subject-matter jurisdiction is proper only when (1) a plaintiff’s claim involves a federal question, or (2) there is diversity among the parties.” Davis v. Ryan Oaks Apartment, 357 F. App’x 237, 238 (11th Cir. 2009) (citing 28 U.S.C. §§ 1331, 1332). Plaintiff’s Complaint presents neither federal question nor diversity jurisdiction.

Plaintiff makes no claims as to diversity of citizenship. Although Plaintiff proclaims that the alleged conduct violates “the 14th amendment of the Constitution,” Plaintiff fails to state any nonfrivolous or substantial violation of his constitutional rights, and therefore federal jurisdiction cannot be based on federal question jurisdiction. “[E]ven if a claim appears to invoke the federal question jurisdiction of the district court, the claim may be dismissed for lack of subject matter jurisdiction if ‘. . . such a claim is wholly insubstantial

and frivolous.’” McQueary, 812 F. App’x at 913 (quoting Blue Cross & Blue Shield of Ala. v. Sanders, 138 F.3d 1347, 1352 (11th Cir. 1998)). In other words, “subject matter jurisdiction is lacking [] if the claim has no plausible foundation[.]” Id. (quoting Blue Cross & Blue Shield of Ala., 138 F.3d at 1352). The test is whether “the alleged cause of action is so ‘patently without merit’ as to justify the court’s dismissal for lack of jurisdiction.” Id. (quoting McGinnis v. Ingram Equip. Co., 918 F.2d 1491, 1494 (11th Cir. 1990) (en banc)).

Here, the factual allegations appear to involve a grievance concerning the lack of public transportation in certain Alabama counties. Plaintiff claims the lack of counties “using buses with at least 50 stops” violates the Fourteenth Amendment; but he does not plead facts to support this conclusion or to explain how this conduct violates this amendment.

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Brenda W. Davis v. Ryan Oaks Apartment
357 F. App'x 237 (Eleventh Circuit, 2009)
Blue Cross & Blue Shield v. Sanders
138 F.3d 1347 (Eleventh Circuit, 1998)
Tannenbaum v. United States
148 F.3d 1262 (Eleventh Circuit, 1998)
University of South Alabama v. American Tobacco Co.
168 F.3d 405 (Eleventh Circuit, 1999)
Cockrell v. Sparks
510 F.3d 1307 (Eleventh Circuit, 2007)
Miller v. Donald
541 F.3d 1091 (Eleventh Circuit, 2008)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
McNeil v. United States
508 U.S. 106 (Supreme Court, 1993)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Robert Procup v. C. Strickland
792 F.2d 1069 (Eleventh Circuit, 1986)
Terrell McGinnis v. Ingram Equipment Company, Inc.
918 F.2d 1491 (Eleventh Circuit, 1990)
Gladys L. Cok v. Family Court of Rhode Island
985 F.2d 32 (First Circuit, 1993)
McKinnes v. American International Group, Inc.
420 F. Supp. 2d 1254 (M.D. Alabama, 2006)
Lyman S. Hopkins v. St. Lucie County School Board
399 F. App'x 563 (Eleventh Circuit, 2010)
Jamaal Ali Bilal v. Geo Care, LLC
981 F.3d 903 (Eleventh Circuit, 2020)

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Pugh v. Autauga, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pugh-v-autauga-almd-2025.