Stokes v. Adam
1:24-cv-03223
D. MarylandJun 3, 2025Background
- David Stokes, a pro se plaintiff, filed suit against Carolyn Adams and Patricia Powell, employees of the Circuit Court for Baltimore City, Maryland.
- Stokes alleged his rights under the Fourteenth Amendment were violated when he was included in the jury pool, causing him emotional harm, and sought removal from the pool, damages, and punitive damages.
- The complaint alleged federal question and diversity jurisdiction, citing 42 U.S.C. § 1983 and the ADA, but sought only $10,000 in damages.
- Defendants moved to dismiss for lack of subject matter jurisdiction, asserting Eleventh Amendment immunity and failure to state a claim.
- Stokes filed a notice of appeal before the motions were resolved; the appeal was dismissed for failure to prosecute and the case returned to the district court.
- The court reviewed motions to appoint counsel, for summary judgment, and to dismiss; no hearing was held.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject matter jurisdiction (diversity) | Diversity exists, $10,000 claimed | Amount-in-controversy not met; no diversity | No diversity jurisdiction |
| Subject matter jurisdiction (federal) | § 1983 and ADA create federal question | Defendants immune as state employees | Eleventh Amendment bars these claims |
| Viability of claims (12(b)(6)) | Rights violated by jury inclusion | No facts alleged connecting statutes to conduct | Complaint fails to state a claim |
| Appointment of counsel/summary judgment | Entitled to counsel/summary judgment | No grounds shown; moot if no jurisdiction | Moot, as complaint dismissed |
Key Cases Cited
- Kerns v. United States, 585 F.3d 187 (4th Cir. 2009) (explaining distinction between facial and factual challenges to jurisdiction)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (setting pleading standard for Rule 12(b)(6))
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for pleadings)
- Bd. of Trustees of Univ. of Ala. v. Garrett, 531 U.S. 356 (2001) (Congress's ability to abrogate Eleventh Amendment immunity)
- Will v. Michigan Dep’t of State Police, 491 U.S. 58 (1989) (official-capacity suits as suits against the state)