Rowe v. Nevada Office of Unemployment

CourtDistrict Court, D. Nevada
DecidedMarch 29, 2024
Docket2:23-cv-01189
StatusUnknown

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

Bluebook
Rowe v. Nevada Office of Unemployment, (D. Nev. 2024).

Opinion

2 UNITED STATES DISTRICT COURT 3 DISTRICT OF NEVADA 4 * * * 5 Michael Rowe, Case No. 2:23-cv-01189-RFB-DJA 6 Plaintiff, 7 Order v. and 8 Report and Recommendation State of Nevada, et al., 9 Defendants. 10 11 Before the Court is Plaintiff Michael Rowe’s amended complaint. (ECF No. 13). 12 Plaintiff’s amended complaint does not state a claim upon which relief can be granted. The Court 13 recommends dismissing Defendants the State of Nevada; the Nevada Department of 14 Employment, Training, and Rehabilitation Security Division (“DETR”); and Chris Sewell, 15 Kristine K. Nelson, Thomas Susich, and Jen Sarafina in their capacities as employees and officers 16 of DETR with prejudice. The Court also dismisses Plaintiff’s claims against Attorney General 17 Aaron Ford, Deputy Attorney General Todd Weiss, and Governor Joseph Lombardo without 18 prejudice and with leave to amend. 19 I. Legal standard. 20 Upon granting an application to proceed in forma pauperis, courts additionally screen the 21 complaint under § 1915(e). Federal courts are given the authority to dismiss a case if the action is 22 legally “frivolous or malicious,” fails to state a claim upon which relief may be granted, or seeks 23 monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2). 24 When a court dismisses a complaint under § 1915, the plaintiff should be given leave to amend 25 the complaint with directions as to curing its deficiencies, unless it is clear from the face of the 26 complaint that the deficiencies could not be cured by amendment. See Cato v. United States, 70 27 F.3d 1103, 1106 (9th Cir. 1995). 1 Rule 12(b)(6) of the Federal Rules of Civil Procedure provides for dismissal of a 2 complaint for failure to state a claim upon which relief can be granted. Review under Rule 3 12(b)(6) is essentially a ruling on a question of law. See Chappel v. Lab. Corp. of Am., 232 F.3d 4 719, 723 (9th Cir. 2000). A properly pled complaint must provide a short and plain statement of 5 the claim showing that the pleader is entitled to relief. Fed.R.Civ.P. 8(a)(2); Bell Atlantic Corp. v. 6 Twombly, 550 U.S. 544, 555 (2007). Although Rule 8 does not require detailed factual 7 allegations, it demands “more than labels and conclusions” or a “formulaic recitation of the 8 elements of a cause of action.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Papasan v. 9 Allain, 478 U.S. 265, 286 (1986)). The court must accept as true all well-pled factual allegations 10 contained in the complaint, but the same requirement does not apply to legal conclusions. Iqbal, 11 556 U.S. at 679. Mere recitals of the elements of a cause of action, supported only by conclusory 12 allegations, do not suffice. Id. at 678. Where the claims in the complaint have not crossed the 13 line from conceivable to plausible, the complaint should be dismissed. Twombly, 550 U.S. at 570. 14 Allegations of a pro se complaint are held to less stringent standards than formal pleadings 15 drafted by lawyers. Hebbe v. Pliler, 627 F.3d 338, 342 & n.7 (9th Cir. 2010) (finding that liberal 16 construction of pro se pleadings is required after Twombly and Iqbal). 17 Federal courts are courts of limited jurisdiction and possess only that power authorized by 18 the Constitution and statute. See Rasul v. Bush, 542 U.S. 466, 489 (2004). Under 28 U.S.C. 19 § 1331, federal courts have original jurisdiction over “all civil actions arising under the 20 Constitution, laws, or treaties of the United States.” Cases “arise under” federal law either when 21 federal law creates the cause of action or where the vindication of a right under state law 22 necessarily turns on the construction of federal law. Republican Party of Guam v. Gutierrez, 277 23 F.3d 1086, 1088-89 (9th Cir. 2002). Whether federal-question jurisdiction exists is based on the 24 “well-pleaded complaint rule,” which provides that “federal jurisdiction exists only when a 25 federal question is presented on the face of the plaintiff’s properly pleaded complaint.” 26 Caterpillar, Inc. v. Williams, 482 U.S. 386, 392 (1987). Under 28 U.S.C. § 1332(a), federal 27 district courts have original jurisdiction over civil actions in diversity cases “where the matter in 1 different states.” Generally speaking, diversity jurisdiction exists only where there is “complete 2 diversity” among the parties; each of the plaintiffs must be a citizen of a different state than each 3 of the defendants. Caterpillar Inc. v. Lewis, 519 U.S. 61, 68 (1996). 4 II. Discussion. 5 Plaintiff sues: (1) the State of Nevada; (2) the DETR Security Division; (3) Kristine K. 6 Nelson in her capacity as the Administrator of DETR Security Division; (4) Thomas Susich in his 7 capacity as the chairperson of the board for review for DETR; (5) Christopher Sewell in his 8 capacity as the Director of the Nevada Department of Unemployment Insurance, a division of 9 DETR; (6) Aaron D. Ford in his capacity as Nevada State Attorney General and the attorney for 10 DETR; (7) Todd M. Weiss in his capacity as Nevada State Deputy Attorney General and attorney 11 for DETR; (8) Jen Sarafina in her capacity as attorney for DETR; and (9) Governor Joseph 12 Lombardo. (ECF No. 13 at 3-4). Plaintiff alleges that his employment was terminated in May of 13 2023 and that he immediately filed for unemployment benefits.1 (Id. at 5). Plaintiff asserts that 14 he spoke with a DETR adjudicator who informed Plaintiff that he would receive benefit 15 payments, but the payments never came. (Id.). Plaintiff received a letter from DETR denying his 16 claim for unemployment benefits and stating that the basis for denying the claim was because 17 Plaintiff quit his job, even though Plaintiff was let go. (Id. at 6). Plaintiff appealed the denial on 18 July 15, 2023 and Plaintiff asserts that DETR refused to process his appeal in a timely manner. 19 (Id.). Plaintiff alleges three causes of action against all Defendants: (1) violation of the Due 20 Process Clause of the Fourteenth Amendment; (2) unemployment insurance fraud; and 21 (3) negligence. Plaintiff invokes Nevada’s waiver of its sovereign immunity under NRS 22 § 41.031. (Id. at 7-9). 23 24 25 26 27 1 Plaintiff asserts that he was fired after being imprisoned for a false arrest. (ECF No. 13 at 5). However, Plaintiff does not assert any claims related to his arrest or imprisonment so the Court A. Plaintiff’s claims against the State, DETR, and DETR officials and employees in 1 their official capacity.

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550 U.S. 544 (Supreme Court, 2007)
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Hebbe v. Pliler
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Bluebook (online)
Rowe v. Nevada Office of Unemployment, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rowe-v-nevada-office-of-unemployment-nvd-2024.