Lamas v. Huffman

Background

Erich S. Lamas, a New York resident proceeding without a lawyer, filed a complaint invoking diversity jurisdiction, which allows a federal court to hear certain disputes between citizens of different states when more than $75,000 is at stake. The complaint identifies Steve Huffman as the chief executive officer of an unnamed social-media platform.

Lamas alleged claims involving product liability and negligent design, a business tort, violations of New York General Business Laws §§ 349 and 350, and other tortious conduct. He alleged that the platform’s algorithmic systems, recommendation engines, and content-moderation structures were designed to promote controversial or harmful content to increase engagement and advertising revenue. He also alleged that employees acting under Huffman’s instructions filed false spam reports against his business email provider, resulting in the suspension of his business email account for several weeks. He sought $100 million in compensatory damages, punitive damages, and injunctive relief.

Lamas also moved for permission to participate in electronic case filing and submitted a request for a pre-discovery subpoena under Rule 27 of the Federal Rules of Civil Procedure. The court had already granted his request to proceed without paying filing fees in advance.

Subject-Matter Jurisdiction

The court held that the complaint did not establish federal-question jurisdiction because Lamas did not bring claims under federal law and the allegations did not show an obvious federal claim.

The court also held that Lamas did not allege enough facts to establish diversity jurisdiction. Lamas stated that he resided in New York, which suggested that his domicile was in New York, but he did not allege where Huffman was domiciled. The court found that the statement that the defendants were citizens of California and other states was too general, particularly because Huffman was the only named defendant. The court also instructed that any amended complaint should clarify the request for $100 million in compensatory damages.

The court therefore dismissed the complaint for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3), with 30 days’ leave to replead. The court stated that Lamas could amend by providing facts showing diverse citizenship and satisfying the amount-in-controversy requirement. If he did not amend within the allowed time, the Clerk would be directed to enter judgment.

Other Motions

The court granted Lamas’s motion for permission to file documents electronically. After registration, court documents and documents filed by other parties would be served through electronic notice at his designated email address rather than by postal mail.

The court denied Lamas’s Rule 27 request. Rule 27 permits limited discovery to preserve known testimony when a person expects to bring a federal-court action but cannot yet bring it and the testimony is at risk of being lost. Lamas did not identify anyone he wanted to depose or describe the expected testimony. The court also found that he was seeking unknown information rather than preserving known testimony, and that his concerns about possible destruction of evidence were too conclusory to show a sufficient risk of loss.

Disposition

The complaint was dismissed for lack of subject-matter jurisdiction, with 30 days’ leave to replead. The electronic-filing motion was granted, and the Rule 27 motion was denied. The court directed the Clerk to keep the matter open on the docket until a civil judgment is entered.