Matthew Jones v. Crisis Intervention Services
687 F. App'x 121
3rd Cir.2017Background
- Pro se plaintiff Mathew Jones sued Crisis Intervention Services (CIS) in D. Del., alleging five 2015 incidents: false mental-health diagnoses, improper removal from his home, and administration of medication without consent.
- Jones asserted state tort claims, violations of federal criminal statutes, and constitutional claims (First and Eighth Amendments), seeking $100,000 (typed $1,00,000).
- CIS moved to dismiss under Fed. R. Civ. P. 12(b); Jones moved for summary judgment. The District Court granted CIS's motion and denied Jones relief.
- The District Court held constitutional claims barred by Eleventh Amendment immunity because CIS was a state agency; state-law tort claims lacked federal subject-matter jurisdiction due to nondiverse parties and no federal question.
- The court rejected Jones's attempt to base jurisdiction on federal criminal statutes, finding he lacked standing to prosecute or impose criminal liability on CIS.
- The District Court denied leave to amend as futile; Jones appealed. The Third Circuit summarily affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether CIS is subject to suit on Jones's constitutional claims | Jones asserted constitutional violations (First, Eighth) by CIS | CIS is a state agency entitled to Eleventh Amendment immunity | Court: CIS immune; constitutional claims dismissed |
| Whether federal criminal statutes confer private civil jurisdiction | Jones cited federal criminal statutes to impose liability on CIS | Criminal statutes do not create private civil cause of action; prosecution is for U.S. Attorney | Court: No standing to pursue criminal statutes; not a basis for § 1331 jurisdiction |
| Whether federal subject-matter jurisdiction exists for state tort claims | Jones relied on state torts alleging battery/false diagnosis/false imprisonment | Parties are non-diverse and no federal question exists | Court: No federal jurisdiction over state tort claims; dismissal appropriate |
| Whether amendment of complaint should be allowed | Jones sought leave to amend after dismissal | CIS and District Court argued amendment would be futile | Court: Denial of leave to amend was not an abuse of discretion |
Key Cases Cited
- P. R. Aqueduct and Sewer Auth. v. Metcalf & Eddy, Inc., 506 U.S. 139 (Eleventh Amendment bars suit against state or state agencies absent waiver)
- Will v. Michigan Department of State Police, 491 U.S. 58 (state is not a "person" under § 1983 for purposes of suit)
- United States v. Friedland, 83 F.3d 1531 (3d Cir.) (prosecution of federal crimes is the role of U.S. Attorney)
- Linda R.S. v. Richard D., 410 U.S. 614 (private citizen lacks standing to seek criminal prosecution)
- Great W. Mining & Mineral Co. v. Fox Rothschild LLP, 615 F.3d 159 (3d Cir.) (standards for denying leave to amend reviewed for abuse of discretion)
- Maliandi v. Montclair State Univ., 845 F.3d 77 (3d Cir.) (de novo review standard for Rule 12(b)(6) dismissal)
- Fowler v. UPMC Shadyside, 578 F.3d 203 (3d Cir.) (pleading standards and de novo review of dismissal)