Ryan Russell v. Solid Rock Realtors, Greg Keirsey, Fake Buyer, and Chad Hopping

Summary

The court dismissed without prejudice a pro se plaintiff’s claims arising from an allegedly fraudulent real estate transaction. The court held that the complaint did not establish federal-question jurisdiction because it asserted only state-law claims, and did not establish diversity jurisdiction because it failed to allege the defendants’ citizenship or an amount in controversy exceeding $75,000.

Holdings

1. The complaint did not establish federal-question jurisdiction because it asserted only state-law contract and tort claims and identified no claim arising under federal law.
2. The complaint did not establish diversity jurisdiction because it failed to allege the defendants' citizenship, complete diversity among the parties, or that the amount in controversy exceeded $75,000.
3. When the court determines that subject-matter jurisdiction is lacking, it must dismiss the action, and the dismissal here was without prejudice.

Questions Presented

1. Whether the complaint established federal-question jurisdiction when it alleged only state-law contract and tort claims.
2. Whether the complaint established diversity jurisdiction by alleging complete diversity of citizenship and an amount in controversy exceeding $75,000.
3. Whether the court was required to dismiss the action without prejudice for lack of subject-matter jurisdiction.

Disposition

dismissed