Rockett v. Hegseth

CourtDistrict Court, N.D. Texas
DecidedMarch 14, 2025
Docket3:25-cv-00384
StatusUnknown

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

Bluebook
Rockett v. Hegseth, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

BEVERLY J. ROCKETT, § PLAINTIFF, § § V. § CIVIL CASE NO. 3:25-CV-384-K-BK § PETE HEGSETH, ET AL., § DEFENDANTS. §

FINDINGS, CONCLUSIONS AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE

Pursuant to 28 U.S.C. § 636(b) and Special Order 3, this pro se civil action was referred to the United States magistrate judge for case management, including the entry of findings and a recommended disposition. Upon review of the relevant pleadings and applicable law, this action should be DISMISSED WITHOUT PREJUDICE for lack of subject matter jurisdiction. I. BACKGROUND On February 14, 2025, Plaintiff Beverly J. Rockett filed a complaint against the Secretary of Defense Pete Hegseth, the U.S. Department of Defense, and the Army And Air Force Exchange Service (“AAFES”). Doc. 3 at 1. She avers that the Court ruled against her in an earlier employment discrimination action against AAFES, her former employer. Rockett v. Esper, No. 3:20-CV-1502-C-BK, 2022 WL 774036, at *1 (N.D. Tex. Feb. 15, 2022), rec. adopted, 2022 WL 768630 (N.D. Tex. Mar. 14, 2022), appeal dismissed, No. 22-10504, 2022 WL 17037663 (5th Cir. Oct. 18, 2022). Rockett now attempts to invoke this court’s federal-question jurisdiction under: “28 U.S.C. § 1331; 28 U.S.C. § 1346; 31 U.S. Code § 3729 – False claims; 18 U.S.C. § 1621 Perjury and False Statements 18 U.S.C. § 1001, and other emotional distress.” Doc. 3 at 1. She asserts this case arises as result “of the False Claims, Defamation and Making of False Damaging Statements against plaintiff.” Doc. 3 at 2. Rocket then alleges defamation against her former supervisors and a human resources representative. Doc. 3 at 2-3. She requests compensatory and punitive damages. Doc. 3 at 3. Upon review, the Court concludes that subject matter jurisdiction is lacking. Thus, this

action should be dismissed sua sponte. II. ANALYSIS A. Jurisdiction is Lacking Although Rockett paid the filing fee, the Court should always examine, sua sponte, if necessary, the threshold question of whether it has subject matter jurisdiction. The Lamar Co., L.L.C. v. Mississippi Transp. Comm'n, 976 F.3d 524, 528 (5th Cir. 2020); FED. R. CIV. P. 12(h)(3) (“If the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.”). Unless otherwise provided by statute, a federal district court has subject-matter jurisdiction over (1) a federal question arising under the Constitution, a federal

law, or a treaty, see 28 U.S.C. § 1331, or (2) a case in which there is complete diversity of citizenship between parties and the matter in controversy exceeds $75,000, see 28 U.S.C. § 1332. “Under the well-pleaded complaint rule, ‘a federal court has original or removal jurisdiction only if a federal question appears on the face of the plaintiff’s well-pleaded complaint; generally, there is no federal jurisdiction if the plaintiff properly pleads only a state law cause of action.’” Gutierrez v. Flores, 543 F.3d 248, 251-52 (5th Cir. 2008). Further, the plaintiff, as the party asserting subject-matter jurisdiction, bears the burden of establishing that subject matter jurisdiction exists. See Willoughby v. U.S. ex rel. U.S. Dep’t of the Army, 730 F.3d 476, 479 (5th Cir. 2013). The Court must also liberally construe pleadings filed by pro se litigants. See Erickson v. Pardus, 551 U.S. 89, 94 (2007) (noting pro se pleadings are “to be liberally construed” and “held to less stringent standards than formal pleadings drafted by lawyers”); Cf. FED. R. CIV. P. 8(e) (“Pleadings must be construed so as to do justice.”). Even under the most liberal construction, however, Rockett has not alleged facts that establish federal question or diversity jurisdiction.

“A federal question exists only [in] those cases in which a well-pleaded complaint establishes either that federal law creates the cause of action or that the plaintiff’s right to relief necessarily depends on resolution of a substantial question of federal law.” Singh v. Duane Morris LLP, 538 F.3d 334, 337-38 (5th Cir. 2008) (citation and internal quotation marks omitted). Rockett’s complaint, however, contains no factual allegations that support federal question jurisdiction. At best, Rockett alleges only state law defamation claims arising from an employment dispute. While Rockett vaguely cites to federal statutes, she does not identify any substantial constitutional or federal statutory violation, as noted infra. Thus, her allegations are insufficient to invoke the Court’s federal question jurisdiction. See Girard v. CitiMortgage, Inc.,

No. 12-CV-4264-N, 2013 WL 5873297, at *2 (N.D. Tex. Nov. 1, 2013) (Godbey, J.) (adopting magistrate judge’s dismissal recommendation because plaintiff’s “single passing reference” to a federal statute did not constitute a cause of action, and was not “sufficient to support the exercise of federal question jurisdiction”). Indeed, “federal courts are without power to entertain claims otherwise within their jurisdiction if they are so attenuated and unsubstantial as to be absolutely devoid of merit . . . .” Hagans v. Levine, 415 U.S. 528, 536-37 (1974) (internal citation and quotation marks omitted); see Murphy v. Inexco Oil Co., 611 F.2d 570, 573 (5th Cir. 1980) (“[T]he assertion that the claim involves [a federal] question must be more than incantation.”). B. False Claims Act If Rockett seeks to plead a qui tam claim under the False Claims Act, her request lacks any legal basis and thus cannot support a federal cause of action. Doc. 3 at 1 (citing 31 U.S.C. § 3729). The False Claims Act is a federal anti-fraud statute that prohibits the knowing submission of false or fraudulent claims for payment to the federal government. See Henderson v. Wells

Fargo Bank, N.A., 974 F. Supp. 2d 993, 1016 (N.D. Tex. 2013). However, Rockett does not complain that the Defendants presented a false or fraudulent claim for payment to the United States. Rather, she contends that her supervisors and a human resources representative defamed her character. Doc. 3 at 2-3. That notwithstanding, as a pro se litigant, Rocket cannot proceed as a relator in a False Claims Act “qui tam” action on behalf of the United States. See United States ex rel. Mergent Servs. v.

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Bluebook (online)
Rockett v. Hegseth, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rockett-v-hegseth-txnd-2025.