Christopher Edward Hallett v. State of Ohio
711 F. App'x 949
| 11th Cir. | 2017Background
- Christopher Hallett, proceeding pro se, filed a civil-rights complaint in federal district court.
- District court dismissed the complaint sua sponte for lack of subject-matter jurisdiction under Fed. R. Civ. P. 12(h)(3).
- Hallett asserted federal jurisdiction under Bivens and § 1983 and raised a due-process grievance; district court found these assertions conclusory or otherwise deficient.
- The district court gave Hallett an opportunity to amend to plead diversity jurisdiction; he failed to properly allege citizenship and amount in controversy.
- The district court concluded defendants were not identified as federal actors (Bivens) and Hallett did not allege state action (§ 1983); dismissal was affirmed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal question jurisdiction exists under Bivens | Hallett claimed Bivens relief for constitutional violations | Defendants (and court) noted no federal officials were named | Dismissed — Bivens unavailable because no federal officials were named |
| Whether § 1983 provides jurisdiction | Hallett claimed constitutional deprivations | Court found no allegations showing defendants acted under color of state law; claims were conclusory | Dismissed — § 1983 not established (no state action, conclusory pleading) |
| Whether diversity jurisdiction exists | Hallett attempted diversity after court's prompt | Hallett failed to allege citizenship (not just residence) and amount > $75,000 | Dismissed — diversity not properly pleaded |
| Whether dismissal denied due process | Hallett argued dismissal violated his due process rights | Court explained it was ensuring subject-matter jurisdiction as required | Denied — no colorable due-process claim; court properly ensured jurisdiction |
Key Cases Cited
- Nicholson v. Shafe, 558 F.3d 1266 (11th Cir. 2009) (standard of review for subject-matter-jurisdiction dismissals)
- Oxford Asset Mgmt., Ltd. v. Jaharis, 297 F.3d 1182 (11th Cir. 2002) (conclusory allegations insufficient to avoid dismissal)
- Nat’l Parks Conservation Ass’n v. Norton, 324 F.3d 1229 (11th Cir. 2003) (district court must dismiss sua sponte when lacking subject-matter jurisdiction)
- Blue Cross & Blue Shield of Ala. v. Sanders, 138 F.3d 1347 (11th Cir. 1998) (frivolous or immaterial federal claims may be dismissed)
- Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (U.S. 1971) (federal officials may be sued in individual capacity for constitutional violations)
- Vt. Agency of Nat. Res. v. United States ex rel. Stevens, 529 U.S. 765 (U.S. 2000) (Eleventh Amendment bars suits against nonconsenting states)
- United States v. Kozminski, 487 U.S. 931 (U.S. 1988) (scope and purpose of Thirteenth Amendment)
- Molinos Valle Del Cibao, C. por A. v. Lama, 633 F.3d 1330 (11th Cir. 2011) (burden to prove diversity jurisdiction and requirement to allege citizenship, not residence)