Tekisha Rousseaux Castellanos v. Sandia Frame & Unibody Alignment, Inc.

Summary

The United States District Court for the District of New Mexico dismissed Plaintiff Tekisha Rousseaux Castellanos’s claims against Sandia Frame & Unibody Alignment, Inc. without prejudice for lack of subject-matter jurisdiction. The court concluded that Plaintiff had not established federal-question, diversity, or supplemental jurisdiction and had not filed an amended complaint curing the jurisdictional defects.

Holdings

1. Supplemental jurisdiction under 28 U.S.C. § 1367 is available only in a civil action in which the federal court has original jurisdiction; a separate subsequent action cannot obtain supplemental jurisdiction merely because it shares a nucleus of operative facts with another federal action.
2. The complaint did not establish federal-question jurisdiction because it identified no federal statutory or constitutional provision as the basis of plaintiff's claims and alleged no facts showing that the claims arose under federal law.
3. The complaint did not establish diversity jurisdiction because it failed to allege facts showing that plaintiff and defendant were citizens of different states, even though plaintiff asserted that damages exceeded $75,000.
4. The action had to be dismissed without prejudice because the court lacked subject-matter jurisdiction.

Questions Presented

1. Whether the complaint established federal-question jurisdiction under 28 U.S.C. § 1331.
2. Whether the complaint established diversity jurisdiction under 28 U.S.C. § 1332.
3. Whether supplemental jurisdiction under 28 U.S.C. § 1367 could exist based on a separate related federal action.
4. Whether the action had to be dismissed without prejudice for lack of subject-matter jurisdiction.

Disposition

dismissed