Sanders v. Baker

CourtDistrict Court, E.D. Michigan
DecidedJune 23, 2025
Docket4:24-cv-12314
StatusUnknown

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

Bluebook
Sanders v. Baker, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

JERROLL SANDERS, Plaintiff, Case No. 24-12314 Honorable Shalina D. Kumar v. Magistrate Judge Curtis Ivy, Jr.

KIMBERLY BAKER et al., Defendants.

ORDER GRANTING PLAINTIFF’S MOTION FOR RECONSIDERATION (ECF NO. 26), VACATING ORDER OF DISMISSAL (ECF NO. 25), AND REOPENING CASE

I. Introduction Pro se plaintiff Jerroll Sanders filed this diversity action against defendants Kimberly Baker, Carlos Hamilton, Gary Hamilton, Terra Page, and Deborah Cobb, asserting claims of slander and libel, tortious interference with contract, malicious prosecution, restitution for physical assault, restitution for theft of money, harassment, and invalidation of will and asset seizure. ECF No. 1. On October 8, 2024, the Court ordered Sanders to show cause why her complaint should not be dismissed for lack of subject matter jurisdiction after a review of the complaint showed the parties were not diverse. See ECF No. 8. Sanders responded to the order Page 1 of 8 to show cause and asserted the Court has diversity jurisdiction over her claims because she is domiciled in Missouri. ECF No. 14, PageID.137. In

support of her assertion, Sanders provided the Court with a copy of an expired Missouri driver’s license, see id. at PageID.139, and claimed she is “physically present in Missouri when not caring for her elderly parents in

Detroit.” Id. at PageID.137. The Court was not persuaded and dismissed Sanders’ complaint without prejudice for want of subject matter jurisdiction. ECF No. 25.

Pursuant to Federal Rule of Civil Procedure 59(e) and Eastern District of Michigan Local Rule 7.1(h), Sanders moves the Court to

reconsider its decision to dismiss her case and provides additional documentation to support her assertion of diversity jurisdiction. For the reasons that follow, the Court grants the motion.

II. Standard of Review

Under Rule 59(e), a court may alter or amend a judgment based on: (1) a clear error of law; (2) newly discovered evidence; (3) an intervening change in controlling law; or (4) a need to prevent manifest injustice. Leisure Caviar, LLC v. U.S. Fish & Wildlife Serv., 616 F.3d 612, 615 (6th

Page 2 of 8 Cir. 2010). A motion under Rule 59(e) is not, however, a vehicle for presenting new legal arguments that could have been raised before a

judgment was issued. Roger Miller Music, Inc. v. Sony/ATV Publ'g, LLC, 477 F.3d 383, 395 (6th Cir. 2007); Leisure Caviar, 616 F.3d at 616 (noting movant “cannot use a Rule 59 motion to raise arguments which could, and

should, have been made before judgment issued”). In the Sixth Circuit, “[t]he grant or denial of a Rule 59(e) motion is within the informed discretion of the district court, reversible only for abuse.” Betts v. Costco Wholesale Corp., 558 F.3d 461, 467 (6th Cir. 2009) (quoting Scotts Co. v. Central

Garden & Pet Co., 403 F.3d 781, 788 (6th Cir. 2005)). Local Rule 7.1(h)(2) articulates that motions for reconsideration of non-final orders are disfavored, must be filed within 14 days after the entry

of the order, and may be brought only upon the following grounds: (A) The court made a mistake, correcting the mistake changes the outcome of the prior decision, and the mistake was based on the record and the law before the court at the time of its prior decision;

(B) An intervening change in controlling law warrants a different outcome; or

(C) New facts warrant a different outcome and the new facts could not have been discovered with reasonable diligence before the prior decision. Page 3 of 8 E.D. Mich. LR 7.1(h)(2). A motion for reconsideration is not a proper means “to re-hash old arguments.” Smith ex rel. Smith v. Mt. Pleasant Pub. Schs.,

298 F. Supp. 2d 636, 637 (E.D. Mich. 2003). “Fundamentally, ‘a motion for reconsideration is not a second bite at the apple[.]’” Masjid Malcolm Shabazz House of Worship, Inc. v. City of Inkster, 2022 WL 866402, at *7

(E.D. Mich. March 23, 2022) (quoting Collins v, Nat’l Gen. Ins. Co., 834 F. Supp. 2d 632, 641 (E.D. Mich. 2011)).

III. Analysis Sanders requests the Court reconsider its order (ECF No. 25)

dismissing her complaint without prejudice for lack of subject matter jurisdiction. Sanders asserts the Court erred in “its jurisdictional analysis on all fronts…” by: (1) relying on Sanders’ use of her Detroit address in her

pleadings; (2) rejecting her expired Missouri driver’s license as evidence of domicile; (3) citing a 2017 case previously filed by Sanders as a basis for denying diversity jurisdiction; and (4) using Sanders’ statement that she spends 95% of her time in Michigan is its determination that the parties

were not diverse. ECF No. 26, PageID.374-376.

Page 4 of 8 The party seeking the federal forum has the burden of establishing federal jurisdiction. “It is to be presumed that a cause lies outside [the

federal court’s] 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 citation omitted).

When a litigant cannot establish the diversity of the parties, the Court is not permitted to “presume the existence of federal jurisdiction.” Howery v. Allstate Ins. Co., 243 F.3d 912, 919 (5th Cir. 2001). For purposes of diversity jurisdiction, citizenship is synonymous with

domicile. Kaiser v. Loomis, 391 F.2d 1007, 1009 (6th Cir.1968). “[A] change in domicile requires only the concurrence of (1) physical presence at the new location with (2) an intention to remain there indefinitely, or the

absence of any intention to go elsewhere.” Holmes v. Sopuch, 639 F.2d 431, 433 (8th Cir. 1981) (citation omitted). “Even though a party may have several places of residence, he or she may have only one domicile at a given time.” Chappelle v. Beacon

Communications Corp., 683 F.Supp. 179, 181 (S.D.N.Y.1994) (citing Williamson v. Osenton, 232 U.S. 619, 625 (1914)). A domicile is distinguished from a residence by the “permanency and scope” of a party's

Page 5 of 8 presence at either location. It is “the place where a person dwells and which is the center of his domestic, social, and civil life.” Id. at 181 (citations

omitted). In determining domicile, the Court must focus on a party’s intent and the entire course of their conduct. “Items to examine include, but are not

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Sanders v. Baker, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanders-v-baker-mied-2025.