Williams v. American Commercial Lines
21-30609
| 5th Cir. | May 24, 2022Background
- Pro se plaintiff Robert H. Williams sued fifteen corporate defendants and two individuals alleging racketeering and multiple federal offenses (RICO, obstruction, false statements, wire fraud, witness tampering, etc.).
- The district court denied Williams' request to proceed in forma pauperis and a magistrate judge recommended dismissal either for lack of subject-matter jurisdiction or for failure to state a claim under Fed. R. Civ. P. 12(b)(6).
- The district court adopted the recommendation but expressly dismissed the case with prejudice for lack of subject-matter jurisdiction.
- The Fifth Circuit construed Williams' complaint liberally but agreed the pleadings contained no facts establishing a federal question or complete diversity required for federal jurisdiction.
- The panel held that dismissal for lack of subject-matter jurisdiction must be without prejudice and that dismissing with prejudice was error.
- The Fifth Circuit VACATED the district court’s judgment and REMANDED for proceedings consistent with its opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Federal subject-matter jurisdiction | Williams invoked federal statutes (RICO and various federal criminal provisions) to confer federal-question jurisdiction | Defendants argued the complaint pleads no facts supporting a federal question or complete diversity | No federal-question or complete diversity alleged; federal jurisdiction lacking |
| Effect of dismissal for lack of jurisdiction | Williams sought relief in federal court (claims adjudicated on merits implicitly) | Defendants accepted dismissal but district court dismissed with prejudice | Dismissal for lack of subject-matter jurisdiction is without prejudice; district court erred in dismissing with prejudice; VACATE and REMAND |
Key Cases Cited
- Mitchell v. Bailey, 982 F.3d 937 (5th Cir. 2020) (dismissal for lack of subject-matter jurisdiction should be without prejudice)
- Wolcott v. Sebelius, 635 F.3d 757 (5th Cir. 2011) (when 12(b)(1) and 12(b)(6) are asserted together, resolve jurisdiction first)
- Heaton v. Monogram Credit Card Bank of Georgia, 231 F.3d 994 (5th Cir. 2000) (a court without jurisdiction cannot render a merits judgment)
- Marts v. Hines, 117 F.3d 1504 (5th Cir. 1997) (distinguishing in forma pauperis dismissals and when dismissals may be with prejudice)