BIENAIME
v.
WELLS FARGO BANK
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A plaintiff sued Wells Fargo Bank alleging the bank's software produced inaccurate information resulting in a $225 charge. The district court found it lacked subject-matter jurisdiction because the claim appeared to arise under state law and the amount in controversy ($225) fell short of the $75,000 diversity jurisdiction threshold.
The court lacks subject-matter jurisdiction and must dismiss the action without prejudice because: (1) no federal claim is discernable from the complaint, and (2) the amount in controversy ($225) does not exceed the $75,000 threshold required for diversity jurisdiction.
“A federal district court must have jurisdiction to decide a dispute [...] If a court determines that jurisdiction is lacking, the court must dismiss the action.”
Establishes the mandatory requirement that federal courts have subject-matter jurisdiction and the obligation to dismiss when it is absent.
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Join FLexlaw to unlock all legal intelligenceThe plaintiff alleges that Wells Fargo Bank's software produced inaccurate information that resulted in a $225 charge against her. She filed suit in f…
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Order
The plaintiff sues Wells Fargo Bank, Doc. 1, and applies to proceed without prepaying fees or costs, Doc. 2. She alleges Wells Fargo's software produced inaccurate information that resulted in a $225 charge against her. Doc. 1 at 4.
A federal district court must have jurisdiction to decide a dispute. Arbaugh v. Y&H Corp., 546 U.S. 500, 514 (2006). If a court determines that jurisdiction is lacking, the court must dismiss the action. Fed. R. Civ. P. 12(h)(3). The dismissal must be without prejudice. Stalley ex rel. U.S. v. Orlando Reg’l Healthcare Sys., Inc., 524 F. 3d 1229, 1232 (11th Cir. 2008).
A federal court may have jurisdiction under a specific statutory grant, federal-question jurisdiction under 28 U.S.C. § 1331, or diversity jurisdiction under 28 U.S.C. § 1332(a). Baltin v. Alaron Trading Corp., 128 F. 3d 1466, 1469 (11th Cir. 1997).
Jurisdiction under § 1331 is known as “federal question” jurisdiction. That statute permits a federal district court to exercise jurisdiction over a civil action "arising under" federal law. 28 U.S.C. § 1331. An example of a civil action arising under federal law is a civil action claiming patent infringement in violation of federal patent law.
Jurisdiction under § 1332 is known as “diversity" jurisdiction. That statute permits a federal district court to exercise jurisdiction over a civil action between citizens of different states involving an amount in controversy exceeding $75,000. 28 U.S.C. § 1332(a)(1). An example of a civil action over which a court would have diversity jurisdiction is a civil action between a Florida citizen and a Georgia citizen claiming damages of $76,000 for negligence under Florida common law.
Here, the Court does not appear to have federal-question jurisdiction because no federal claim is discernable from the facts alleged in the complaint. See Doc. 1. The Court does not have diversity jurisdiction because, at a minimum, the amount in controversy does not exceed $75,000. See Doc. 1 at 4 (alleging $225 as the amount in controversy).
By November 4, 2024, the plaintiff must show cause why the Court should not dismiss the action without prejudice for lack of subject-matter jurisdiction. If the plaintiff fails to timely show cause, the Court may dismiss the action. The Court defers ruling on the application to proceed without prepaying fees or costs, Doc. 2, until a determination on subject-matter jurisdiction.
The Court's website offers resources for unrepresented litigants, including a Guide for Proceeding Without a Lawyer. In addition, the
Jacksonville Federal Court Bar Association operates a Legal Information Program through which unrepresented litigants can obtain information from a lawyer on a limited basis for free. To participate, the plaintiff may contact the clerk's office at (904) 549-1900.
Ordered in Jacksonville, Florida, on October 1, 2024.
c: Liseberthe Gessica BienAime 7400 Powers Ave., Apt. 583 Jacksonville, FL 32217
PATRICIA D. BARKSDALE
United States Magistrate Judge
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Arbaugh v. Y & H Corp., 546 U.S. 500 (U.S. 2006)
- Stalley v. Orlando Reg'l Healthcare Sys., Inc., 524 F.3d 1229 (11th Cir. 2008)
- Aubie Baltin v. Alaron Trading Corp., 128 F.3d 1466 (11th Cir. 1997)