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