Lopes v. Reddit, Inc.
- Lucy Koh
- 5:20-cv-08086
- U.S. District Court · Northern District of California
- 3
In Lopes v. Reddit, Inc., Judge Koh dismissed Lopes’s amended complaint without leave to amend because it did not establish federal-question or diversity jurisdiction.
Cornelius Lopes and the defendants named in the case: Reddit, Inc., Erin Baldassari, Ryan Thompsen, Bay Area News Group, San Jose Mercury News, and First Media.
What happened
In Lopes v. Reddit, Inc., Cornelius Lopes, representing himself, sued Reddit, Inc., and other defendants. A magistrate judge gave him four opportunities to correct problems in his complaints and explain why the federal court had jurisdiction.
Lopes’s later filings asserted claims such as defamation, emotional distress, and the right to publicity, which the court treated as state-law claims. He also did not show that all parties were citizens of different states, so he did not establish either of the jurisdictional bases the court considered.
The court adopted the magistrate judge’s recommendation and dismissed Lopes’s amended complaint without leave to amend, finding that another amendment would be futile. Judge Lucy Koh issued the order.
The detailed version
- Lopes v. Reddit, Inc. · No. 5:20-cv-08086
- Lucy Koh
- Aug. 3, 2021
Background
Cornelius Lopes filed the case against Reddit, Inc., Erin Baldassari, Ryan Thompsen, Bay Area News Group, San Jose Mercury News, and First Media. Lopes proceeded without a lawyer. Magistrate Judge Nathanael M. Cousins held a case-management conference that Lopes did not attend, screened Lopes’s complaints, and allowed four opportunities to amend.
Judge Cousins’s third screening order directed Lopes to revise the complaint’s format and establish subject-matter jurisdiction—the court’s legal authority to hear the case. The order warned that the case would be recommended for dismissal if Lopes could not establish jurisdiction through a federal-law claim or diversity jurisdiction.
Jurisdictional Deficiencies
Judge Cousins’s Report and Recommendation concluded that Lopes still had not established subject-matter jurisdiction. The district court also considered Lopes’s later filing, even though it was difficult to follow and was filed after the deadline.
The court determined that the asserted claims—including defamation, slander, intentional infliction of emotional distress, negligent infliction of emotional distress, and the right to publicity—arose under state law and therefore did not establish federal-question jurisdiction. The court also found that Lopes had not demonstrated complete diversity of citizenship between the parties. In particular, the filing did not appear to identify the citizenship of any defendant.
Ruling
No party objected to the Report and Recommendation within the allowed period. Judge Lucy Koh found the recommendation well-founded and concluded that giving Lopes a fifth opportunity to amend would be futile. The court therefore adopted the Report and Recommendation and dismissed Lopes’s amended complaint, docket entry 14, without leave to amend, for lack of subject-matter jurisdiction.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.