Capital One v. Sandra D. Bell
- Clarke
- 7:25-cv-07159
- U.S. District Court · Southern District of New York
- 3
In Capital One v. Sandra D. Bell, Judge Clarke remanded the case to state court and denied Bell’s requested alternative relief.
Capital One and Sandra D. Bell; the action was returned from federal court to the Supreme Court of the State of New York, Orange County.
What happened
In Capital One v. Sandra D. Bell, Sandra D. Bell, representing herself, removed Capital One’s state-court action to federal court, claiming federal-question jurisdiction. The court ordered her to explain why the case should not be returned to state court.
Bell pointed to an underlying dispute and her communications with Capital One. The court found those allegations insufficient because the complaint was styled as a breach-of-contract case and did not assert a federal claim. Federal defenses or counterclaims also could not create federal-question jurisdiction.
The court denied Bell’s requests for permission to file a separate federal complaint and to stay or consolidate the proceedings. Judge Jessica G. L. Clarke ordered the case remanded to the Supreme Court of the State of New York, Orange County, and directed the clerk to close the federal case.
The detailed version
- Capital One v. Sandra D. Bell · No. 7:25-cv-07159
- Clarke
- Oct. 28, 2025
Background
On August 27, 2025, Sandra D. Bell, proceeding without a lawyer, filed a notice removing Capital One’s action from the Supreme Court of the State of New York, Orange County. Bell asserted that removal was proper because the case involved a federal question.
On September 22, 2025, the court ordered Bell to explain in writing why the case should not be remanded, or returned, to state court. The court identified her failure to allege a federal question on the face of Capital One’s complaint. Bell responded on October 6, 2025, citing an underlying dispute with Capital One and her communications with the company.
Subject-Matter Jurisdiction
The court held that Bell’s allegations did not establish federal subject-matter jurisdiction. Federal-question jurisdiction is generally determined from the plaintiff’s properly pleaded complaint, rather than from a defendant’s defenses or counterclaims. The court noted that Bell acknowledged the complaint was styled as a breach-of-contract claim and lacked federal claims. The court concluded that any federal statutory defenses or counterclaims Bell might assert were insufficient to support removal.
Because the federal court lacked subject-matter jurisdiction, the court was required to remand the case to state court.
Alternative Relief
Bell also requested an opportunity to file a separate federal complaint asserting her federal rights, along with a stay of or consolidation with the state-court proceedings. The court denied that requested relief as improper. It explained that Bell did not need permission from this court to file a separate federal lawsuit, but that any such lawsuit would have to comply with applicable procedural and substantive requirements. The court also stated that it lacked power to consolidate proceedings outside its jurisdiction.
The court further noted that federal injunctions stopping state-court proceedings are exceedingly rare under the Anti-Injunction Act, subject to three narrow exceptions. It did not rule that an injunction should or should not issue in this matter.
Disposition
The court remanded the case to the Supreme Court of the State of New York, Orange County. It also directed the clerk to terminate Bell’s filing at ECF No. 13 and close the federal case. Jessica G. L. Clarke signed the order as United States District Judge.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.