Tanna v. Tanna

CourtDistrict Court, M.D. Alabama
DecidedMay 21, 2025
Docket2:25-cv-00280
StatusUnknown

This text of Tanna v. Tanna (Tanna v. Tanna) 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
Tanna v. Tanna, (M.D. Ala. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION SHAREEN TANNA, ) ) Plaintiff, ) ) v. ) CASE NO. 2:25-cv-00280-RAH-KFP ) [WO] SHAILESH J. TANNA, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER On April 14, 2025, Shareen Grice/Tanna removed this domestic relations case to this Court from the domestic relations division of the Circuit Court of Elmore County, Alabama. After careful consideration, this action is REMANDED for lack of subject matter jurisdiction. BACKGROUND Plaintiff bases removal on 28 U.S.C. §§ 1441 and 1443, 42 U.S.C. §§ 1983 and 1985, and the Elmore County Circuit Court’s conduct and management of Plaintiff’s domestic-relations dispute with her ex-husband. Plaintiff asserts that the circuit court’s consolidation of her “pro se contempt and modification motion” with an existing underlying action without notifying Plaintiff violated “state and federal rules of civil procedure, den[ied] [her] the right to participate meaningfully in her own case,” and therefore violated her due process rights under the Fourteenth Amendment and her civil rights for “racial justice and equal protection.” (Doc. 1 at 2.) Because of its ongoing obligation to assess the existence of subject matter jurisdiction, the Court ordered Plaintiff to show cause as to why this action should not be remanded for lack of jurisdiction. (See doc. 4.) In that order, the Court identified two concerns: the fact that (1) this is a domestic-relations case which is an exception to federal jurisdiction, see United States v. Windsor, 570 U.S. 744, 767 (2013), and (2) a plaintiff generally cannot remove a case from state to federal court. See 28 U.S.C. §§ 1441(a), 1443. Plaintiff timely filed her response, in which she argues that subject matter jurisdiction exists because, according to her, “[t]his is not a conventional family court matter,” as “[i]t involves deeply rooted violations of federally protected rights, including due process, civil rights under 42 U.S.C. § 1983, and statutory protections under the Violence against Women Act (VAWA).” (Doc. 5 at 1.) While the Court is sympathetic to Plaintiff’s alleged circumstances, the Court does not have jurisdiction over this case.1 STANDARD OF REVIEW Federal courts may only adjudicate cases as “authorized by Constitution and statute.” See Gunn v. Minton, 568 U.S. 251, 256 (2013) (quoting Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994)). In other words, unless Article III of the Constitution provides the jurisdictional basis, federal courts have no authority to act without a statutory grant of subject matter jurisdiction. Univ. of S. Ala. v. Am. Tobacco Co., 168 F.3d 405, 409 (11th Cir. 1999). And in the context of removal, whenever there are uncertainties of a federal court’s exercise of subject matter jurisdiction, remand is the appropriate course of action. Burns v. Windsor Ins. Co., 31 F.3d 1092, 1095 (11th Cir. 1994).

1 The Court notes that Plaintiff appears to attempt to name new parties in her motion for emergency relief and in her response to the Court’s show cause order. But the action that she removed is her child-custody dispute, which the Court has no jurisdiction over, and none of her allegations state that the named defendant in the domestic-relations case caused her alleged harm. Plaintiff’s injury must be “fairly traceable” to the Defendant’s alleged conduct. Spokeo, Inc. v. Robins, 578 U.S. 330, 338 (2016). And that is not the case here. DISCUSSION Despite Plaintiff’s characterization of the case, the Court lacks subject matter jurisdiction. A district court has original jurisdiction based either on a federal question or diversity of citizenship. See 28 U.S.C. §§ 1331, 1332. And in limited circumstances, a defendant may also remove a case based on civil rights violations. See 28 U.S.C. §§ 1343, 1357, 1443; Jimenez v. Wizel, 644 F. App’x 868, 869 (11th Cir. 2016) (“[M]atters regarding enforcement of constitutional rights related to equality may properly be removed to federal court.” (citing 28 U.S.C. § 1443)). Here, Plaintiff characterizes her domestic-relations case as one of constitutional and civil rights infringements. But she, as the plaintiff, cannot remove her own case, and the removed case, at its core, is a domestic relations dispute over which the Court lacks subject matter jurisdiction. As an initial matter, the relevant removal statutes here—Sections 1441(a) and 1443—do not allow a plaintiff to remove her own case to federal court. See 28 U.S.C. § 1441(a) (“[A]ny civil action brought in a State court of which the district courts of the United States have original jurisdiction, may be removed by the defendant . . . , to the district court of the United States[.]” (emphasis added); id. § 1443 (“Any of the following civil actions . . . commenced in a State court may be removed by the defendant . . . .” (emphasis added); see also Rigaud v. Broward Gen. Med. Ctr., 346 F. App’x 453, 454 (11th Cir. 2009) (per curiam) (affirming a district court’s sua sponte dismissal of the case because it “was required to dismiss [the] action” where it was the plaintiff who removed the case from state court). Because it was Plaintiff who removed her own action, the action must be remanded. See Rigaud, 346 F. App’x at 454. Further, even if Plaintiff was a proper removing party, the case still must be remanded because it is a domestic relations case over which the Court lacks subject matter jurisdiction. “[F]ederal courts generally dismiss cases involving divorce and alimony, child custody, visitation rights, establishment of paternity, child support, and enforcement of separation or divorce decrees still subject to state court modification.” Ingram v. Hayes, 866 F.2d 368, 369 (11th Cir. 1988) (per curiam) (citations omitted) (holding although diversity of citizenship existed, the district court properly abstained from exercising jurisdiction in domestic relations case). Courts “willingly apply the domestic relations exception to federal questions and constitutional issues involving intra-family disputes” and “decline jurisdiction over federal questions which would deeply involve them in adjudicating domestic affairs.” Ingram, 866 F.2d at 371. This “domestic relations exception mandates abstention when the district court could become enmeshed in factual disputes.” Id. at 372 (internal quotations and citation omitted); Jimenez, 644 F.

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Jacqueline Burns v. Windsor Insurance Co.
31 F.3d 1092 (Eleventh Circuit, 1994)
Gunn v. Minton
133 S. Ct. 1059 (Supreme Court, 2013)
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Bluebook (online)
Tanna v. Tanna, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tanna-v-tanna-almd-2025.