Summary
The Eastern District of Missouri dismissed Teresa Lockett’s pro se action against her sister concerning allegedly withheld Social Security benefits. The court held that it lacked subject-matter jurisdiction because there was no diversity jurisdiction, no adequate federal question, no final Social Security decision for review under 42 U.S.C. § 405(g), and no viable Federal Tort Claims Act basis. The court granted leave to proceed in forma pauperis and denied appointment of counsel as moot.
Topics
Practice areas
Questions Presented
- Whether the district court had subject matter jurisdiction over Lockett's state-law conversion claim against her Missouri-resident sister.
- Whether the court had jurisdiction over any claim concerning the Social Security Administration's handling of Lockett's benefits absent a final decision by the Commissioner of Social Security or an applicable waiver of sovereign immunity.
- Whether any claim under the Federal Tort Claims Act could proceed against the Social Security Administration or against the United States without compliance with the applicable prerequisites.
Holdings
- The court lacked federal subject matter jurisdiction over Lockett's claim against Jackson because diversity jurisdiction was unavailable where both parties were Missouri citizens and the amount in controversy was below $75,000, and a state-law conversion claim did not independently create federal-question jurisdiction.
- The court lacked jurisdiction over any claim against the Social Security Administration because the agency was protected by sovereign immunity absent a waiver, and the complaint did not identify a final decision of the Commissioner reviewable under 42 U.S.C. § 405(g), exhaustion of administrative remedies, or a colorable constitutional claim.
- Any claim under the Federal Tort Claims Act was subject to dismissal because the Social Security Administration could not be sued under the FTCA, and the complaint did not show that the required prerequisites for an FTCA action had been satisfied.
Key quotations
“If this Court determines at any time that it lacks subject matter jurisdiction, it must dismiss the action.”
“And a state court claim of conversion, by itself, does not state a federal question.”
“This Court lacks diversity jurisdiction under 28 U.S.C. § 1332, as both she and her sister are citizens of Missouri, and the amount in controversy in this action is less than the required $75,000.”
Factual background
Lockett alleged that her sister, Jacqueline Jackson, was her power of attorney, court-appointed guardian, and Social Security representative payee. She claimed that Jackson withheld approximately $2,991 in SSI funds, failed to pay rent for two months, retained her identification, and prevented her from accessing money. The complaint also suggested dissatisfaction with the Social Security Administration's handling of her benefits, but it did not identify a final administrative decision or a clear federal claim.
Procedural history
Lockett filed the action on August 28, 2025, alleging that Jacqueline Jackson, purportedly acting as her Social Security representative payee, withheld approximately $2,991 in SSI benefits and failed to pay rent. Lockett also appeared to seek relief concerning the Social Security Administration's handling of her benefits. The district court reviewed the complaint under the in forma pauperis screening statute, granted in forma pauperis status, concluded that no federal jurisdictional basis was adequately alleged, dismissed the case, and certified that an appeal would not be taken in good faith.