Binion v. United States Department of Agriculture (MAG+)
2:16-cv-00657
M.D. Ala.Sep 7, 2017Background
- Five pro se plaintiffs sued USDA and the Secretary seeking declaratory and injunctive relief tied largely to enforcement or interpretation of the Pigford class-action consent decree and related USDA administrative processes.
- Plaintiffs allege USDA denied timely ALJ hearings and seek orders for expedited hearings, review of ALJ decisions, production of a "running record," and constitutional invalidation of the county committee/organizational hierarchy used by USDA.
- Defendants moved to dismiss for lack of subject-matter jurisdiction (Rule 12(b)(1)) as to Pigford claims and for improper venue (Rule 12(b)(3)) as to non-Pigford claims; they also asserted alternative motions for summary judgment and failure to state a claim.
- The magistrate treated the jurisdictional challenge as a facial 12(b)(1) attack and considered whether courts other than the D.C. court (which entered the Pigford consent decree) have authority to enforce or adjudicate Pigford-related claims.
- The magistrate found the court lacks subject-matter jurisdiction over all Pigford-related claims and dismissed them without prejudice; separately, Ferrell Oden’s non-Pigford administrative/discrimination claims were dismissed without prejudice for improper venue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether this court has jurisdiction to hear/enforce Pigford consent-decree claims | Plaintiffs sought enforcement/relief under the consent decree in this court (ALJ hearings, record production, injunctions) | Only the D.C. court (or Court of Federal Claims in some contexts) retained jurisdiction to enforce the Pigford consent decree; no independent federal jurisdiction here | Dismissed for lack of subject-matter jurisdiction; Pigford claims must be litigated in the court that retained jurisdiction (D.C.) or are not cognizable here |
| Whether plaintiffs may obtain relief (injunctive/declaratory) tied to consent decree in a different federal district | Plaintiffs implicitly argued this court could adjudicate relief | Defendants argued enforcement of consent decrees is limited and ancillary jurisdiction does not supply an independent basis absent retained jurisdiction | Court held enforcing the settlement falls outside its jurisdiction absent D.C. court retention; dismissed Pigford claims without prejudice |
| Whether Oden’s non-Pigford discrimination claims are in proper venue here | Oden argued his claims belong in the Court of Federal Claims or otherwise should proceed here | Defendants argued venue is improper in Middle District of Alabama and identical litigation is pending in Court of Federal Claims | Oden’s non-Pigford claims dismissed without prejudice for improper venue (not transferred) |
| Whether severance or repleader is appropriate for misjoined/non-Pigford claims | Plaintiffs sought bifurcation or transfer of Pigford claims | Defendants sought severance and dismissal of unrelated claims | Court declined to create a new severed case and instead dismissed unrelated non-Pigford claims without prejudice as futile; no repleader ordered due to jurisdiction/venue defects |
Key Cases Cited
- Pigford v. Glickman, 185 F.R.D. 82 (D.D.C. 1999) (original Pigford class-action settlement and consent decree)
- Pigford v. Glickman, 206 F.3d 121 (D.C. Cir. 2000) (appellate decision affirming aspects of Pigford litigation)
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (enforcement of settlement agreements requires independent basis for federal jurisdiction unless court retained jurisdiction)
- Anago Franchising, Inc. v. Shaz, LLC, 677 F.3d 1272 (11th Cir. 2012) (enforcing settlement agreements generally falls outside ancillary jurisdiction)
- Am. Disability Ass'n, Inc. v. Chmielarz, 289 F.3d 1315 (11th Cir. 2002) (court may retain jurisdiction to enforce consent decree through contempt)
- Univ. of S. Alabama v. Am. Tobacco Co., 168 F.3d 405 (11th Cir. 1999) (trial court obligated to inquire sua sponte into subject-matter jurisdiction)