Willie Jackson v. State of Nevada, et al.

Opinion

3 * * *

4 WILLIE JACKSON, Case No. 3:25-CV-00066-ART-CLB

5 Plaintiff, ORDER DENYING PLAINTIFF’S MOTION FOR BREACH OF CONTRACT 6 v. AND SANCTIONS

7 STATE OF NEVADA, et al., [ECF Nos. 74, 75]

8 Defendants.

9 10 Before the Court is Plaintiff Willie Jackson’s (“Jackson”) motions for breach of 11 contract and request for sanctions. (ECF Nos. 74, 75.) Jackson previously entered into a 12 global settlement agreement, (ECF No. 68), and his case was dismissed with prejudice 13 once the terms of the settlement were satisfied, (ECF No. 73). Jackson now alleges 14 Defendants breached the settlement agreement by not permitting him to attend Jumu’ah 15 services at the agreed upon time and asks the Court to intervene. (ECF Nos. 74, 75.) 16 However, because this case was dismissed the Court lacks jurisdiction to hear Jackson’s 17 motions and they must be denied. 18 “Federal courts are courts of limited jurisdiction” and possess only the power 19 authorized by the Constitution and United States statutes. Kokkonen v. Guardian Life Ins. 20 Co. of Am., 511 U.S. 375, 377 (1994). This power cannot be expanded by judicial decree. 21 Id. (citing Am. Fire & Cas. Co. v. Finn, 341 U.S. 6 (1951)). It is well settled that federal 22 courts presume a cause of action lies outside of their limited jurisdiction, and that the party 23 asserting jurisdiction has the burden of establishing it. Id. (first citing Turner v. Bank of N. 24 Am., 4 U.S. 8, 11 (1799); and then citing McNutt v. Gen. Motors Acceptance Corp., 298 25 U.S. 178, 182-83 (1936)). Federal courts must have either an independent (constitutional 26 or statutory) basis for jurisdiction over a cause of action or jurisdiction pursuant to their 27 inherent powers or ancillary jurisdiction. Id. at 378, 381-82. 1 ancillary jurisdiction to enforce a settlement agreement merely because the subject of the 2 settlement was a federal lawsuit. Id. at 381. The Court stated that ancillary jurisdiction is 3 generally permissible under only two circumstances: “(1) to permit disposition by a single 4 court of claims that are, in varying respects and degrees, factually interdependent; and 5 (2) to enable a court to function successfully, that is, to manage its proceedings, vindicate 6 its authority, and effectuate its decrees.” Id. at 379-80 (internal citations omitted). As to 7 the first circumstance, the Court found that it would not be particularly efficient for a federal 8 court to exercise jurisdiction over what is essentially a breach of contract claim because 9 the facts underlying the breach of a settlement agreement “have nothing to do with” the 10 facts of the underlying case. Id. at 380. 11 As to the second circumstance, the Court held that a federal court has ancillary 12 jurisdiction to enforce a settlement agreement “if the parties’ obligation to comply with the 13 terms of the settlement agreement had been made part of the order of dismissal — either 14 by separate provision (such as a provision ‘retaining jurisdiction’ over the settlement 15 agreement) or by incorporating the terms of the settlement agreement in the order.” Id. at 16 381. Jurisdiction exists in such a case because a breach of the settlement agreement 17 violates a court order. Mallard Auto. Grp. Ltd. v. United States, 343 F. Supp. 2d 949, 955 18 (D. Nev. 2004) (citing Kokkonen, 511 U.S. at 375). If the federal court has no independent 19 jurisdiction over the settlement agreement, and absent making the settlement agreement 20 part of the dismissal order, “enforcement of the settlement agreement is for state courts.” 21 Id. (quoting Kokkonen, 511 U.S. at 382). 22 “The judge’s mere awareness and approval of the terms of the settlement 23 agreement” is not enough to make the settlement agreement part of the dismissal order. 24 Kokkonen, 511 U.S. at 381. Nor is language in the order of dismissal stating that the 25 dismissal is “based on the settlement” enough for the federal court to retain jurisdiction. 26 O’Connor v. Colvin, 70 F.3d 530, 532 (9th Cir. 1995). “Indeed, even a district court’s 27 expressed intention to retain jurisdiction is insufficient to confer jurisdiction if that intention 1| 49F.3d 1430, 1433 (9th Cir. 1995) (finding that the district court did not retain jurisdiction 2| to enforce the settlement agreement despite pronouncing on the record he would “act as 3 a czar’ over the agreement because the order of dismissal merely stated: “Counsel 4 having informed the court that this action has been settled, this action is dismissed with 5 | prejudice”). 6 IT IS THEREFORE ORDERED that, because the Court lacks jurisdiction, 7 | Jackson’s motion for breach of contract, (ECF No. 74), and motion for sanctions, (ECF 8| No. 75), are DENIED. 9 IT IS FURTHER ORDERED that no additional documents are to be filed in this closed case. The Clerk is directed to RETURN AS UNFILED any further documents received in this closed case. 42 DATED: July 8, 2026 13 | » 14 15 UNITED STATES'‘MAGISTRATE JUDGE 16 17 18 19 20 21 22 23 24 25 26 27 28