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STATE OF NEW JERSEY v. JOHN DOE
3:24-cv-11491
D.N.J.
May 2, 2025
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Background

  • Defendant John Doe removed a civil action from New Jersey Superior Court to federal court, asserting federal question jurisdiction.
  • The original case involved US Bank Cust for Actlien Holding suing Singh, with the State of New Jersey also being joined due to a possible property interest.
  • Doe's Notice of Removal did not include the underlying complaint and referenced federal law only in relation to his own anticipated counterclaims against the state court's procedures.
  • Doe failed to timely pay the filing fee or apply to proceed in forma pauperis, eventually paying after a delay.
  • Doe also filed a motion to quash a summons and requested to proceed pseudonymously as "John Doe."

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Federal question jurisdiction for removal No explicit argument; not set forth here Doe claimed violations of his constitutional rights arising from state procedures No jurisdiction; removal improper
Validity of Doe’s counterclaims as basis for removal Not argued; plaintiff silent Doe argued his federal claims justified removal Federal claims in counterclaims insufficient
Motion to quash summons issued to State Not addressed Doe sought to quash summons to State, citing procedural issues Motion denied (lacked standing; untimely/moot)
Request to proceed pseudonymously Not addressed Doe sought anonymity citing unspecified privacy concerns Request denied; not exceptional circumstances

Key Cases Cited

  • Caterpillar, Inc. v. Williams, 482 U.S. 386 (federal question removal jurisdiction must be determined from face of the complaint)
  • Gully v. First Nat’l Bank, 299 U.S. 109 (well-pleaded complaint rule governs federal question jurisdiction)
  • Holmes Grp., Inc. v. Vornado Air Circulation Sys., Inc., 535 U.S. 826 (counterclaims cannot supply federal question jurisdiction)
  • Vaden v. Discover Bank, 556 U.S. 49 (federal jurisdiction not based on counterclaims)
  • Doe v. Megless, 654 F.3d 404 (standard for proceeding anonymously in federal court)
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Case Details

Case Name: STATE OF NEW JERSEY v. JOHN DOE
Court Name: District Court, D. New Jersey
Date Published: May 2, 2025
Docket Number: 3:24-cv-11491
Court Abbreviation: D.N.J.