Christina Brinson v. Providence Community Corrections
703 F. App'x 874
| 11th Cir. | 2017Background
- Christina Brinson pled guilty in Wayne County, GA, received fines and four one-year probated sentences, and was referred to Providence Community Corrections (Providence) under a county "user-based fee" Services Agreement.
- The Services Agreement had Providence provide probation services paid by probationers; Wayne County and the state court paid Providence nothing and enforced probationers’ payment duties.
- Brinson sued in federal court seeking (Count I) declaratory relief that O.C.G.A. § 42-8-101(a)(1) and the Services Agreement are unconstitutional/void, and (Count II) damages under Georgia law (money had and received) for fees paid.
- Providence moved to dismiss for lack of subject-matter jurisdiction and failure to state a claim; the district court dismissed Brinson’s complaint with prejudice; Brinson appealed.
- The Eleventh Circuit questioned subject-matter jurisdiction sua sponte: concerns included standing/mootness for declaratory relief because Providence allegedly terminated the Services Agreement and ceased providing services in Wayne County before Brinson filed suit, and unclear federal-question or diversity jurisdiction for the damages claim.
- The court vacated and remanded solely to allow the district court to resolve these jurisdictional issues (standing, mootness, Gunn federal-question analysis, diversity/CAFA issues), declining to reach the merits; a dissent would have decided merits and applied Heck/Bearden principles.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing for declaratory relief | Brinson alleges ongoing risk from private-probation fee scheme and enforcement | Services Agreement terminated and Providence no longer operates there, so no prospective injury | Court doubts standing/mootness; remands for district court to decide jurisdictional facts |
| Justiciability/mootness | Declaratory relief appropriate to invalidate statute/contract and prevent future enforcement | Termination of agreement and cessation of services likely moots declaratory claims | Court finds claims likely moot if no ongoing enforcement; remands for factual resolution |
| Federal-question jurisdiction for damages (Gunn test) | State-law claim raises federal constitutional issues, so federal jurisdiction exists | Gunn requires narrow, substantial federal issue; parties did not brief this; jurisdiction doubtful | Court declines to decide; directs district court to apply Gunn and assess whether state claim "arises under" federal law |
| Diversity/CAFA jurisdiction for damages | Class claims exceed $5M; Brinson’s pleading implies Georgia residency | Complaint lacks full citizenship allegations (plaintiff, class members, defendant incorporation); CAFA exceptions may apply | Court finds diversity/CAFA jurisdiction unclear; remands for district court to develop record and consider exceptions |
Key Cases Cited
- Chacon-Botero v. U.S. Att’y Gen., 427 F.3d 954 (11th Cir.) (courts must inquire into subject-matter jurisdiction whenever doubtful)
- United States v. Rojas, 429 F.3d 1317 (11th Cir.) (federal courts are courts of limited jurisdiction)
- McGee v. Solicitor Gen. of Richmond Cty., Ga., 727 F.3d 1322 (11th Cir.) (standing for prospective/declaratory relief requires a sufficient likelihood of future injury)
- Strickland v. Alexander, 772 F.3d 876 (11th Cir.) (standing is jurisdictional for federal courts)
- Gunn v. Minton, 568 U.S. 251 (U.S.) (federal jurisdiction over state-law claims requires a narrow four-part test)
- McKinnon v. Talladega County, Ala., 745 F.2d 1360 (11th Cir.) (transfer of prisoner can moot declaratory claims against prior custodian)
- Nat’l Adver. Co. v. City of Miami, 402 F.3d 1329 (11th Cir.) (mootness deprives federal court of jurisdiction)
- Belleri v. United States, 712 F.3d 543 (11th Cir.) (vacatur and remand for district court to determine jurisdictional issues)
- Bearden v. Georgia, 461 U.S. 660 (U.S.) (revocation of probation for failure to pay can violate due process for indigents)
- Heck v. Humphrey, 512 U.S. 477 (U.S.) (damages claims that would imply invalidity of an undisturbed conviction/sentence are barred)
- Gagnon v. Scarpelli, 411 U.S. 778 (U.S.) (parole/probation officers have duties to clients’ welfare)
- Marshall v. Jerrico, Inc., 446 U.S. 238 (U.S.) (conflict-of-interest inquiry in due-process contexts)