Washington v. Mayweather
20-30474
| 5th Cir. | Jul 12, 2021Background
- Pro se plaintiff Toren Washington sued Floyd Mayweather and Mayweather Promotions (MP) in federal court under diversity jurisdiction, alleging defendants breached an oral contract to produce and market 67 footwear designs he created.
- Washington alleged economic losses but did not state a dollar value for the contract or the designs in his complaint.
- He later claimed in briefing (not in the complaint) he spent $27,000 to secure the opportunity.
- Floyd Mayweather was not served and did not appear; MP moved to dismiss for lack of personal jurisdiction.
- The district court dismissed the complaint for lack of subject-matter jurisdiction (amount-in-controversy not met) and dismissed MP for lack of personal jurisdiction; Washington appealed, raising jurisdictional, due process, Seventh Amendment, and judicial-bias arguments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject-matter jurisdiction (amount in controversy) | Washington asserts economic loss from breach exceeds federal diversity threshold | Defendants point out complaint alleges no monetary value for contract or designs; amount not pleaded | Affirmed dismissal — amount in controversy not satisfied; dismissal reviewed de novo |
| Personal jurisdiction over MP | Washington contends claims against MP should proceed | MP challenged personal jurisdiction; district court dismissed those claims | Court declined to reach merits of personal-jurisdiction issue because subject-matter jurisdiction failure disposes of case |
| Due process (notice/opportunity to be heard) | Washington says dismissal deprived him of due process | MP notes Washington had opportunity to plead jurisdictional facts and to respond to motions but did not | No due-process violation; failure to respond does not create a due-process problem |
| Seventh Amendment (right to jury) | Washington argues dismissal denied his jury-trial right | Defendants: jurisdictional questions are for the court, not jury | No Seventh Amendment violation; jurisdictional dismissals are for the court, not the jury |
Key Cases Cited
- Randall D. Wolcott, M.D., P.A. v. Sebelius, 635 F.3d 757 (5th Cir. 2011) (dismissal for lack of subject-matter jurisdiction reviewed de novo)
- Liaw Su Teng v. Skaarup Shipping Corp., 743 F.2d 1140 (5th Cir. 1984) (if subject-matter jurisdiction lacking, court need not decide personal jurisdiction)
- In re Air Crash Disaster Near New Orleans, La. on July 9, 1982, 821 F.2d 1147 (5th Cir. 1987) (later panel decisions on related jurisdictional issues)
- Callon Petroleum Co. v. Frontier Ins. Co., 351 F.3d 204 (5th Cir. 2003) (failure to respond in proceedings does not itself create a due-process issue)
- Yohey v. Collins, 985 F.2d 222 (5th Cir. 1993) (claims not adequately briefed are abandoned)
- Menchaca v. Chrysler Credit Corp., 613 F.2d 507 (5th Cir. 1980) (jurisdictional questions fall within the court’s authority)
- Barrett v. Indep. Order of Foresters, 625 F.2d 73 (5th Cir. 1980) (jury has no role regarding dismissals for lack of subject-matter jurisdiction)