Greene v. Simpson

United States District Court, District of Minnesota · August 25, 2025 · No. 0:25-cv-00703

Summary

This Opinion and Order from the U.S. District Court for the District of Minnesota grants defendants' motions to dismiss a pro se lawsuit for lack of subject-matter jurisdiction. The court determines that the plaintiffs failed to adequately allege complete diversity of citizenship and that their asserted federal claims are patently meritless, failing to raise a substantial federal question. Accordingly, the case is dismissed without prejudice, and the plaintiffs' pending motions for sanctions and judicial notice are denied.

Court
United States District Court, District of Minnesota
Writing for the Court
Eric C. Tostrud
Jurisdiction
District of Minnesota
Decision date
August 25, 2025
Docket number
0:25-cv-00703
Procedural posture
motion to dismiss for lack of subject-matter jurisdiction
Standard of review
de novo
Precedential value
nonprecedential
Disposition
dismissed

Topics

subject matter jurisdictionmotions to dismisscivil procedureequal protectionfourteenth amendment

Practice areas

civil procedureconstitutional law

Questions Presented

  1. Whether the district court has subject-matter jurisdiction over the plaintiffs' claims under diversity jurisdiction, federal-question jurisdiction, or supplemental jurisdiction.

Holdings

  1. The court held that the amended complaint fails to establish subject-matter jurisdiction; therefore the motions to dismiss are granted and the action is dismissed without prejudice.

Key quotations

The party seeking to invoke a federal court’s subject matter jurisdiction bears the burden of showing that the court has jurisdiction. (*3)
In analyzing a facial attack, a court restricts itself to the face of the pleadings, and the non‑moving party receives the same protections as it would defending against a motion brought under Rule 12(b)(6). (914)

Factual background

Kyle and Krystle Greene, pro se, sued ten defendants alleging unlawful eviction and seeking title, injunctive relief, sanctions, and damages. Ten defendants filed motions to dismiss, primarily asserting that the complaint failed to establish subject-matter jurisdiction.

Procedural history

The Greenes filed an amended complaint alleging various state-law claims and seeking federal jurisdiction. Defendants filed Rule 12(b)(1) motions to dismiss asserting lack of subject-matter jurisdiction. The district court granted all motions and dismissed the action without prejudice.

Court Document

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