Williams Steele v. 1085 Nelson LLC Apts

Background

Beatrice Shirley Williams Steele proceeded without a lawyer and requested permission to proceed without paying court fees. She originally sued 1085 Nelson LLC Apts., which the opinion says appeared to be her landlord, and its attorney, Ita Flug. The original complaint appeared to concern rent payments, requested repairs, a court-directed payment to the landlord, and alleged violations of her rights.

In an order dated June 5, 2025, the court dismissed the original complaint for lack of subject matter jurisdiction, meaning the court concluded it lacked legal authority to hear the case. The court allowed Williams Steele to file an amended complaint identifying a valid federal claim or establishing the requirements for state-law claims based on diversity jurisdiction.

Williams Steele filed an amended complaint on June 18, 2025, naming 1085 Nelson LLC as the only defendant. She referred to alleged harassment, discrimination, retaliation by landlords, eviction attempts, habitability and repair problems, and the need to maintain or replace household appliances. She also alleged that payments made through a government housing agency, money orders, and payments made through court proceedings were not properly credited. She sought $100,000 for pain and suffering and new appliances.

Court’s Analysis

The court held that the amended complaint did not establish federal-question jurisdiction. Williams Steele did not invoke that form of jurisdiction and did not allege facts suggesting a viable claim arising under federal law. The court had previously explained that she could not bring a constitutional claim under 42 U.S.C. § 1983 against the defendants because they were private parties rather than state actors.

The court also held that the amended complaint did not establish diversity jurisdiction, which can allow a federal court to hear certain state-law disputes involving citizens of different states. Williams Steele alleged that she was a citizen of New York. Because 1085 Nelson LLC is a limited liability company, however, its citizenship depends on the citizenship of each of its members. Williams Steele did not allege the citizenship of any of the LLC’s members. The court therefore concluded that she had not shown complete diversity between the parties.

The court explained that people proceeding without lawyers are generally given an opportunity to amend defective complaints, but that another amendment may be denied when a previous amendment opportunity did not cure the defects. Because Williams Steele had already amended once and the amended complaint gave no indication that another amendment could fix the jurisdictional problems, the court declined to allow another amendment.

Disposition

Judge Louis L. Stanton dismissed the action for lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3). The court directed the clerk to enter judgment. The opinion does not state that the dismissal was with or without prejudice.