REARDON v. DOMONSKI
1:25-cv-00268
| D. Me. | May 28, 2025Background
- Nathan Reardon (Plaintiff) filed a complaint against Adam Domonski (Defendant), his former commercial landlord, alleging defamation and invasion of privacy.
- Plaintiff and Defendant are both residents of Maine.
- Reardon claimed that Domonski published false and defamatory statements and portrayed him in a false light.
- Plaintiff filed to proceed without prepayment of fees, which the court granted.
- The court conducted a preliminary review of the complaint under 28 U.S.C. § 1915(e)(2).
- The complaint was dismissed before service, based on the court's sua sponte jurisdictional review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court has subject matter jurisdiction (diversity jurisdiction) | Court has diversity jurisdiction under 28 U.S.C. § 1332 because parties are citizens of different states | Not stated (court acted sua sponte) | No jurisdiction; case dismissed |
| Whether sufficient facts allege a plausible claim for relief | Complaint is sufficient on its face if facts taken as true | Not stated (not reached) | Not reached, due to dismissal |
| Whether the court should dismiss a pro se complaint for failure to state a claim | Pro se complaint should be liberally construed | Not stated | Not reached, due to dismissal |
| Whether plaintiff should proceed in forma pauperis | Plaintiff is unable to pay filing fees | Not argued | Granted (preliminary review conducted) |
Key Cases Cited
- Neitzke v. Williams, 490 U.S. 319 (1989) (explains dismissals under 28 U.S.C. § 1915 are often sua sponte to spare defendants unnecessary expense)
- Ocasio-Hernandez v. Fortuno-Burset, 640 F.3d 1 (1st Cir. 2011) (sets out standard for considering the sufficiency of a pro se complaint)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must state enough facts to state a claim that is plausible on its face)
- Gunn v. Minton, 568 U.S. 251 (2013) (federal courts have limited jurisdiction only as authorized by Constitution and statute)
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (burden is on party asserting federal jurisdiction to establish it)
- Connectu LLC v. Zuckerberg, 522 F.3d 82 (1st Cir. 2008) (complete diversity of citizenship required for diversity jurisdiction)