Langenderfer v. Roger A. Miller

Background

Geronimo Thomas Langenderfer filed the case in September 2024 against Thomas J. Madden, Nicholas Lumbreras, and Roger A. Miller. He sought approximately $8 million for breach of contract. The opinion states that the case concerned an underlying cannabis contract.

The court previously granted the defendants’ motion to dismiss under Federal Rule of Civil Procedure 12(b)(1), which permits dismissal when a federal court lacks subject-matter jurisdiction, meaning legal authority to hear the dispute. The court directed Langenderfer to file an amended complaint clearly explaining the federal question raised by his claim and warned that the case could be dismissed without prejudice to refiling in state court.

Langenderfer filed an amended complaint on June 16, 2025. The defendants filed a second motion to dismiss under Rule 12(b)(1), again arguing that he had not established subject-matter jurisdiction.

Analysis

The court explained that federal-question jurisdiction generally exists when a civil case arises under the Constitution, federal laws, or treaties. Ordinarily, a federal question must appear on the face of the plaintiff’s properly pleaded complaint. A state-law claim can sometimes qualify if it necessarily raises a substantial, disputed federal issue that a federal court can resolve without disrupting the balance between federal and state authority.

The court found that the amended complaint remained difficult to follow and still appeared to assert a breach-of-contract claim. Although Langenderfer stated that federal-question jurisdiction existed, he did not identify the federal question with enough specificity or explain how the federal jurisdiction standards applied to his case.

The court rejected Langenderfer’s apparent arguments that federal jurisdiction arose from the cannabis contract, his references to himself as a “federal contractor,” his assertion that the parties had a “government contract” or “Presidential Contract,” and documents referring to federal licenses. The court found that these assertions and documents did not show that resolving the contract claim would raise a substantial federal issue or require consideration of federal law.

The court also rejected the argument that federal jurisdiction existed because Langenderfer was affiliated with a tribal government. It explained that the presence of an Indian tribe or individual as a party does not by itself create federal-question jurisdiction. The court concluded that the dispute appeared to require application of state law rather than resolution of a federal issue.

Disposition

The court granted the defendants’ motion to dismiss. Because Langenderfer had already been given an opportunity to amend and still had not established subject-matter jurisdiction, the court dismissed the case against the defendants without leave to amend and without prejudice to refiling in state court. The Clerk was directed to enter judgment for the defendants and close the case. Judge Haywood S. Gilliam, Jr. signed the order.