Arnold v. Attorney General Department of Justice
- Susan Van Keulen
- 5:19-cv-05147
- U.S. District Court · Northern District of California
- 5
Arnold v. United States of America: Judge Van Keulen granted the United States’ motion to dismiss because the allegations did not establish federal jurisdiction, without leave to amend.
Marie Arnold and her daughters were affected by the dismissal of Arnold’s claims against the United States. The United States obtained dismissal of the action without leave to amend.
What happened
In Arnold v. United States of America, Marie Arnold alleged that the United States was negligent toward her and her daughters. She brought claims under the Federal Tort Claims Act and for negligence, seeking ten million dollars in damages.
The United States asked the court to dismiss the case because it lacked authority to hear the claims and because Arnold had not stated a legally sufficient claim. The court ruled that Arnold’s allegations were implausible and could not establish federal jurisdiction. Because of that ruling, the court did not address the United States’ other arguments.
Judge Susan Van Keulen granted the motion to dismiss without leave to amend. The court found that another, more detailed complaint would not fix the problems and directed the clerk to close the file.
The detailed version
- Arnold v. Attorney General Department of Justice · No. 5:19-cv-05147
- Susan Van Keulen
- Feb. 13, 2020
Background
Marie Arnold sued the United States, alleging that it had been negligent toward her and her daughters. She asserted a claim under the Federal Tort Claims Act, a federal law that allows certain lawsuits against the United States for conduct by government employees, and a separate negligence claim. She sought ten million dollars in damages.
The United States moved to dismiss the first amended complaint under Federal Rule of Civil Procedure 12(b)(1), which allows dismissal when a federal court lacks subject-matter jurisdiction, and Rule 12(b)(6), which addresses failure to state a legally sufficient claim. The United States argued that the allegations were not sufficient to invoke federal jurisdiction, that the Federal Tort Claims Act barred claims based on a failure to investigate, and that the Act was the exclusive remedy for Arnold’s negligence allegations.
Court’s analysis
The court focused on subject-matter jurisdiction. It explained that federal courts lack jurisdiction over claims that are wholly insubstantial, obviously frivolous, or completely devoid of merit. The court reviewed Arnold’s allegations that government officials had targeted and abused her and her daughters, failed to investigate threats and other conduct, used electronic harassment, caused exposure to contaminated air and water, and caused physical and psychological harm.
The court found these allegations implausible and concluded that they could not confer subject-matter jurisdiction. It therefore held that it lacked jurisdiction over Arnold’s claims. Because jurisdiction was lacking, the court did not reach the United States’ remaining arguments under Rule 12(b)(6) or concerning the Federal Tort Claims Act.
Amendment and disposition
The court had previously allowed Arnold to amend her complaint. It found that allowing another amendment would be futile because adding more detail about the alleged mind control and other conduct would not cure the jurisdictional problems. The court therefore granted the United States’ motion to dismiss without leave to amend and directed the clerk to close the file.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.