Harris v. Ukoha-Ajike al

Background

Tonie Harris, proceeding without a lawyer, filed a complaint naming Harris individually and the Estate of Stephanie Palmer. The court held that a person proceeding without a lawyer may not bring claims on behalf of an estate in a representative capacity. Harris therefore could not file a claim on behalf of the Palmer Estate.

Jurisdiction concerns

The court explained that federal courts may hear only cases authorized by the Constitution or Congress. It found no diversity jurisdiction because Harris and the defendants are residents of California, so complete diversity was absent. The court also stated that it was unclear whether Harris had asserted a federal-law claim. Although Harris checked the complaint box for a federal-law claim, the court said the complaint did not appear to address one.

Order

The court ordered Harris to show cause—that is, to explain—why the case should not be reassigned to a district judge with a recommendation to dismiss the case for lack of subject-matter jurisdiction. If Harris was asserting a federal-law claim on Harris’s own behalf, the response had to identify the statute and facts supporting that claim. If Harris alleged a sufficient federal claim, the response also had to explain how any state-law claims were connected to it for purposes of supplemental jurisdiction. The written response was due by October 30, 2025.

The court vacated the case-management conference and stated that it would reset the conference later if necessary. It denied Harris’s request to continue the conference as moot. The order did not itself dismiss the case. Judge Sallie Kim signed the order as a United States Magistrate Judge.