Machul v. State of Michigan, 3:16-cv-00173

Pro se plaintiff Benjamin Machul filed a "Petition for Declaratory Judgment" against the State of Michigan and a Benjamin James Machul in federal court.
The magistrate judge recommended dismissal for lack of subject-matter jurisdiction, noting the Declaratory Judgment Act and Rule 57 do not themselves confer jurisdiction.
The magistrate also concluded suits against the State of Michigan in federal court are barred by the Eleventh Amendment.
Machul filed objections arguing (1) the suit sought remedies for alleged state fraud regarding his birth name/process rather than merely clarifying a legal relationship, and (2) constitutional violations (First, Fourth, Fifth, Thirteenth Amendments) confer jurisdiction.
The district court reviewed the R&R de novo, overruled Machul’s objections, adopted the R&R, and dismissed the complaint without prejudice; the court held Machul may not refile against the State in this court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Subject-matter jurisdiction	Machul: federal jurisdiction exists under Declaratory Judgment Act and 28 U.S.C. §§ 2201–2202	Declaratory Act and Rule 57 do not create jurisdiction; plaintiff bears burden to show jurisdiction	Dismissal for lack of subject-matter jurisdiction (R&R adopted)
Eleventh Amendment immunity	Machul: alleges constitutional violations by Michigan; court can hear federal constitutional claims	State of Michigan is immune from suit in federal court under the Eleventh Amendment	Eleventh Amendment bars Machul’s claims against the State in this court; dispositive
Nature of requested relief	Machul: seeks damages and remedies for alleged fraud related to birth name/process	Complaint is titled a petition for declaratory judgment; damages are not declaratory relief	Court notes mismatch; monetary relief would not be proper as framed and cannot be pursued against the State here
Claims against individual defendant	Machul: named Benjamin James Machul as defendant	Complaint does not reasonably identify the individual or alleged acts; no jurisdiction shown	Court finds no reasonable identification or actionable allegations against the individual; claims dismissed

Finley v. United States, 490 U.S. 545 (1989) (party invoking federal jurisdiction bears burden to establish it)
Aldinger v. Howard, 427 U.S. 1 (1976) (limits on federal jurisdiction and proper parties)
Papasan v. Allain, 478 U.S. 265 (1986) (Eleventh Amendment bars certain suits against states)
Exxon Mobil Corp. v. Allapattah Servs., Inc., 545 U.S. 546 (2005) (statutory changes superseding aspects of prior jurisdictional rulings)
Global Tech., Inc. v. Yubei (XinXiang) Power Steering Sys. Co., Ltd., 807 F.3d 806 (6th Cir. 2015) (plaintiff bears burden to show federal jurisdiction)