Endeley v. New York University

Background

Saint Jermaine Endeley filed this action without a lawyer and asked to proceed without prepaying filing fees. He alleged that he enrolled at New York University in 2010, signed a contract with the university, and fulfilled his contractual obligations. He claimed that New York University breached the contract by removing him from classes and canceling his matriculation status. He sought more than $75,000 in damages and attached account statements concerning his attendance between 2010 and 2014.

Jurisdiction

The court explained that federal district courts generally have jurisdiction over claims arising under federal law or disputes between citizens of different states when more than $75,000 is at stake. Endeley invoked diversity jurisdiction, but his complaint acknowledged that both he and New York University were citizens of New York State. That allegation defeated the requirement that the parties be citizens of different states. The court also found that the complaint did not invoke federal-question jurisdiction and contained no facts suggesting a claim arising under federal law.

Rulings

The court dismissed the complaint for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3). It denied leave to amend because the jurisdictional defects could not be cured by amendment. The court denied all outstanding motions as moot, including the request for a remote civil trial, the request to expedite the proceedings, and the request for pro bono counsel. The court separately stated that the motion for a civil trial was denied as moot.

Order to Show Cause

The court reviewed Endeley’s prior litigation history, including earlier related proceedings, and found that he was or should have been aware of the jurisdictional requirement at issue. The court ordered him to submit, within 30 days of the order, a written declaration explaining why he should not be barred from filing further actions against New York University in this court without first obtaining permission when seeking to proceed without paying filing fees. If he did not submit the declaration, or if it did not establish good cause, the stated filing restriction would be imposed. The court had not yet imposed that restriction in this order.

The court certified that any appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. It directed the clerk to keep the matter open until a civil judgment was entered.