Wayne Bell v. U.S. Social Security Administration

CourtDistrict Court, N.D. Florida
DecidedFebruary 27, 2026
Docket3:26-cv-00929
StatusUnknown

This text of Wayne Bell v. U.S. Social Security Administration (Wayne Bell v. U.S. Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, N.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wayne Bell v. U.S. Social Security Administration, (N.D. Fla. 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA PENSACOLA DIVISION

WAYNE BELL,

Plaintiff,

v. Case No. 3:26cv929-TKW-HTC

U.S. SOCIAL SECURITY ADMINISTRATION,

Defendant. ______________________/ REPORT AND RECOMMENDATION Before the Court is Plaintiff Wayne Bell’s motion to remand (Doc. 4) and Defendant Social Security Administration’s (“SSA”) motion to dismiss (Doc. 6). After reviewing the parties’ submissions1 and the relevant law, the undersigned concludes: (1) Bell’s motion to remand should be DENIED, because removal was proper; and (2) the SSA’s motion to dismiss should be GRANTED, because Bell’s claim against the SSA is barred by sovereign immunity. Thus, this case should be DISMISSED without prejudice. I. Background Bell filed this action against the SSA in state court on October 7, 2025. See Escambia County Case No. 2025 SC 7188. He alleges he updated his direct deposit

1 Bell filed a response to the SSA’s motion to dismiss. Doc. 9. information with the SSA on September 16, 2025, but the SSA sent his next monthly disability benefit payment to the wrong bank account. Doc. 1-1 at 1. He claims the

misdirected payment caused a “catastrophe,” and he seeks $3,000 in damages. Id. The SSA removed the case to this Court on February 9, 2026, pursuant to 28 U.S.C. § 1442(a)(1). Doc. 1.

II. Motion to Remand Bell has filed a motion to remand this case to state court. Doc. 4. Liberally construed, the motion argues the Court does not have federal question jurisdiction because Bell’s claim is not based on federal law, and the Court does not have

diversity jurisdiction because the amount in controversy is less than $75,000.2 However, these arguments are meritless because the SSA is not invoking the Court’s federal question or diversity jurisdiction.

Instead, as set forth in the notice of removal, the SSA removed this case under 28 U.S.C. § 1442(a)(1) because it is a federal agency. Section 1442(a)(1) “provides an independent federal jurisdictional basis, allowing for removal of any civil action against a U.S. officer or agency.” Disanto v. Thomas, 693 F. App’x 860, 861 (11th

Cir. 2017); see also Wilson v. Hearos, LLC, 128 F.4th 1254, 1260 (11th Cir. 2025)

2 Bell also claims: (1) he “wasn’t properly notified” of the removal because the removal occurred less than 24 hours before the parties were scheduled to appear for a hearing in state court; and (2) there are two related cases in state court. However, neither the fact that removal occurred immediately before a scheduled state court proceeding nor the fact other related cases are being heard in state court provide a basis for remand. (noting a district court can hear a case if it has federal question jurisdiction, diversity jurisdiction, or jurisdiction under a specific statutory grant) (emphasis added).

Accordingly, because the SSA is a federal agency, removal of this case from state to federal court was proper.3 See Peele v. 17th Judicial Circuit of Fla., 2024 WL 1090604, at *3 (11th Cir. Mar. 13, 2024) (“[T]he case was properly removed to

federal court. The SSA, as a federal agency named as a defendant, was within its statutory right to remove the case to federal court.”) (citing 28 U.S.C. § 1442(a)(1)); Bufkin v. United States, 522 F. App’x 530, 531 (11th Cir. 2013) (“From a jurisdictional standpoint, it is proper to remove a state court action to federal court

if it is directed at a federal agency.”). Bell also asserts the SSA’s February 9 notice of removal was untimely because it was not filed within 30 days of service. Doc. 5; see also 28 U.S.C. §

1446(b)(1) (“The notice of removal of a civil action … shall be filed within 30 days after the receipt by the defendant, through service or otherwise, of a copy of the initial pleading setting forth the claim for relief upon which such action or proceeding is based[.]”). Because the SSA was served with Bell’s complaint on

January 8, the 30-day deadline for removal expired on February 7. However,

3 Although it is unsettled whether a federal agency, like a federal officer, must raise a colorable federal defense to make removal proper under § 1442(a)(1), the Court need not resolve that issue here because the SSA has raised a colorable federal defense—sovereign immunity. See City of Jacksonville v. Dep’t of Navy, 348 F.3d 1307, 1313 n.2 (11th Cir. 2003), (declining to decide the issue because “the Navy in this case has clearly asserted the federal defense of sovereign immunity”). February 7 was a Saturday, which means the deadline was extended to the following Monday, February 9. See Fed. R. Civ. P. 6(a)(1)(C) (explaining that if the last day

of a time period “is a Saturday, Sunday, or legal holiday, the period continues to run until the end of the next day that is not a Saturday, Sunday, or legal holiday”). Thus, even though the SSA filed its notice of removal on February 9—32 days after

service—removal was timely. Based on the foregoing, Bell’s motion to remand should be denied. III. Motion to Dismiss The SSA has also moved to dismiss this case under Fed. R. Civ. P. 12(b)(1),

arguing: (1) Bell has not identified any applicable waiver of sovereign immunity; (2) there is no applicable waiver of sovereign immunity for money damages; and (3) the state court lacked jurisdiction to hear Bell’s claim due to sovereign immunity

and, thus, this Court did not acquire jurisdiction when it was removed. Doc. 6. The undersigned agrees the Court does not have jurisdiction over Bell’s claim due to sovereign immunity.4

4 The determination that removal was proper based on the jurisdictional grant in § 1442(a)(1) is not inconsistent with the determination that this case should be dismissed for lack of jurisdiction based on sovereign immunity. See Bufkin, 522 F. App’x at 531 (“removing an action to federal court may not waive sovereign immunity or equitably estop a sovereign from asserting lack of subject-matter jurisdiction as a defense”); City of Jacksonville, 348 F.3d at 1310-11 (“Congress’ purpose [in enacting § 1442(a)(1)] was clearly to provide a federal forum for the sovereign immunity issue[.]”). “Absent a waiver, sovereign immunity shields the Federal Government and its agencies from suit. Sovereign immunity is jurisdictional in nature.” F.D.I.C. v.

Meyer, 510 U.S. 471, 475 (1994) (citations omitted); see also Jordan v. Def. Fin. & Acct. Servs., 744 F. App’x 692, 695 (11th Cir. 2018) (“Absent a specific waiver of sovereign immunity as to a particular claim filed against the government, a court

lacks subject matter jurisdiction over the suit.”) (citation omitted). “In 42 U.S.C. § 405(g), Congress waived sovereign immunity by giving the federal courts jurisdiction to review and modify or reverse the [SSA’s] decisions.” Jackson v. Astrue, 506 F.3d 1349, 1353 (11th Cir. 2007). Section 405(g) “is the

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Wayne Bell v. U.S. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wayne-bell-v-us-social-security-administration-flnd-2026.