Darren Little v. Sandra Metcalf

Summary

The United States District Court for the Middle District of Tennessee grants Darren Little’s application to proceed in forma pauperis and assesses the statutory filing fee under the Prison Litigation Reform Act. The court dismisses the action without prejudice for lack of subject-matter jurisdiction because the complaint asserts only state-law slander and defamation claims and does not establish federal-question or diversity jurisdiction.

Holdings

1. The court lacked federal-question jurisdiction because slander and defamation are state-law torts and Plaintiff did not assert a federal cause of action.
2. Plaintiff did not establish a basis for diversity jurisdiction, and the face of the complaint showed no apparent basis for federal jurisdiction.
3. A federal court must dismiss an action when it determines that subject-matter jurisdiction is lacking, including when the issue is raised sua sponte.
4. The IFP application was granted, but Plaintiff remained responsible for the full civil filing fee, payable through the PLRA's initial partial payment and installment procedures.

Questions Presented

1. Whether the court had federal-question jurisdiction over Plaintiff's state-law slander and defamation claims.
2. Whether Plaintiff established diversity jurisdiction under 28 U.S.C. § 1332.
3. Whether the action should be dismissed without prejudice for lack of subject-matter jurisdiction.
4. Whether Plaintiff should be permitted to proceed in forma pauperis and pay the filing fee through prisoner-account deductions under the PLRA.

Disposition

dismissed