Wadley v. Meta Platforms Inc

Background

The court had ordered Meta Platforms Inc. to explain why the action should not be sent back to Texas state court for lack of federal jurisdiction. Meta responded by citing a Ninth Circuit decision stating that any non-frivolous federal claim can establish federal-question jurisdiction, even if the claim is later dismissed on its merits.

Wadley’s Texas complaint purported to assert a claim against Meta under the Fourteenth Amendment. The court noted that courts regularly hold that federal constitutional claims against private actors are frivolous when the complaint does not allege that the defendant acted as a state actor. The court held that Wadley failed to allege a non-frivolous federal claim.

Forum Non Conveniens Argument

Meta asked the court to dismiss the case based on forum non conveniens, a doctrine that can allow a court to decline to hear a case when another forum is more appropriate. The court recognized that it could address that issue before deciding subject-matter jurisdiction, but said Meta identified no authority requiring it to do so. The court also found it inappropriate to interpret Meta’s forum-selection clause without briefing from both parties and stated that Texas courts could address those issues after remand.

Disposition

The court remanded the action to the 101st Judicial District Court of Dallas County, Texas. The order did not decide the merits of Wadley’s underlying claim or resolve Meta’s forum non conveniens argument.