Sadat v. Stuart Allan & Associates
Civil Action No. 2016-2146
| D.D.C. | Oct 31, 2016Background
- Plaintiff Mir Nematullah Sadat sued Stuart Allan & Associates (now Stuart-Lippman & Associates, Inc.) in D.C. Superior Court alleging violations of the D.C. equivalent to the federal Fair Credit Reporting Act and sought $2,000 in damages.
- Defendant removed the case to federal district court, asserting federal-question jurisdiction based on alleged FCRA claims and citing 28 U.S.C. §§ 1331, 1441, 1446.
- The removal notice relied in part on a pre-suit letter in which Plaintiff referenced “federal debt collection laws,” but the filed complaint explicitly sought relief under the D.C. statute.
- The district court emphasized that the defendant bears the burden of establishing federal jurisdiction and that removal statutes are construed narrowly.
- The court found no federal-question jurisdiction because the plaintiff’s properly pleaded complaint did not present a federal claim, and no diversity jurisdiction because the amount in controversy ($2,000) was well below $75,000.
- Because subject-matter jurisdiction was lacking, the court ordered remand to D.C. Superior Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the case arises under federal law (federal-question jurisdiction) | Complaint seeks relief under D.C. equivalent statute; no federal claim pleaded | Removal asserts complaint raises FCRA/federal claims (citing pre-suit letter referencing federal laws) | No federal-question jurisdiction: federal law not presented on face of properly pleaded complaint; removal improper |
| Whether diversity jurisdiction exists (amount in controversy) | N/A — Plaintiff seeks $2,000 | Defendant argued for federal jurisdiction generally; did not establish amount > $75,000 | No diversity jurisdiction: amount in controversy ($2,000) far below $75,000 threshold |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (federal courts are courts of limited jurisdiction)
- McNutt v. Gen. Motors Acceptance Corp. of Indiana, 298 U.S. 178 (burden of proving jurisdiction rests on party asserting it)
- Caterpillar, Inc. v. Williams, 482 U.S. 386 (federal jurisdiction depends on plaintiff's well-pleaded complaint)
- Vaden v. Discover Bank, 556 U.S. 49 (federal jurisdiction cannot be predicated on anticipated defenses)
- Shamrock Oil & Gas Corp. v. Sheets, 313 U.S. 100 (removal statute construed narrowly)
- Illinois v. Kerr-McGee Chem. Corp., 677 F.2d 571 (removal statute should be construed against removal)
- Julien v. CCA of Tennessee, Inc., 268 F. Supp. 2d 19 (remand required if defect in removal appears before final judgment)
- Dixon v. Coburg Dairy, Inc., 369 F.3d 811 (if federal jurisdiction is doubtful, remand is necessary)