ROSS
v.
IHEARTMEDIA, INC.
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Pro se plaintiff Michael Ross filed a defamation action against iHeartMedia, Inc. in federal court based on diversity jurisdiction. The court dismissed the complaint without prejudice for lack of subject-matter jurisdiction because both parties were citizens of Texas, destroying complete diversity required for federal jurisdiction.
The court lacked subject-matter jurisdiction because complete diversity of citizenship did not exist. Both the plaintiff and defendant were citizens of Texas, and therefore the court could not exercise diversity jurisdiction under 28 U.S.C. § 1332(a), which requires complete diversity and an amount in controversy exceeding $75,000.
[1] A federal district court must have jurisdiction to decide a dispute, and if jurisdiction is lacking, the court must dismiss the action without prejudice.
[2] Federal courts may exercise jurisdiction under a specific statutory grant, federal-question jurisdiction, or diversity jurisdiction.
Previewing 2 of 5 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“Federal courts are courts of limited jurisdiction and have 'an independent obligation to determine whether subject-matter jurisdiction exists, even in the absence of a challenge from any party.'”
Establishes that courts must sua sponte examine subject-matter jurisdiction regardless of party arguments
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Join FLexlaw to unlock all legal intelligencePlaintiff Michael Ross, a Texas citizen, filed a defamation complaint against iHeartMedia, Inc., also a Texas citizen. Ross cited diversity of citizen…
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Before the Court is pro se Plaintiff Michael Ross’s Complaint. (Doc. 1). This Court construes this as a defamation action. Federal courts are courts of limited jurisdiction and have “an independent obligation to determine whether subject-matter jurisdiction exists, even in the absence of a challenge from any party.” Arbaugh v. Y.H. Corp., 546 U.S. 500, 514 (2006) (citing Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574, 583 (1999)). Plaintiff cites diversity of citizenship as the basis for this Court’s jurisdiction. (Doc. 1 at 3). But diversity jurisdiction only exists where there is complete diversity of citizenship between the parties and the amount in controversy exceeds $75,000, exclusive of interest and costs. See 28 U.S.C. § 1332(a). Here, Plaintiff alleges that he is a citizen of Texas and so is Defendant iHeart Media, Inc. (Doc. 1 at 4). That means there is no diversity of citizenship in this case. Accordingly, the Court finds that Plaintiff has not met his burden of establishing this Court’s subject matter jurisdiction over this action. Accordingly, it is now ORDERED: 1. Plaintiff Michael Ross’s Complaint (Doc. 1) is DISMISSED without prejudice for lack of subject matter jurisdiction. 2. Plaintiff may file an amended complaint on or before September 6, 2024. Failure to do so will cause the Court to close this case without further notice. DONE and ORDERED in Fort Myers, Florida on August 21, 2024.
UNITED STATES DISTRICT JUDGE
Copies: All Parties of Record