Stiles v. Kahn
- Richard Seeborg
- 3:24-cv-00558
- U.S. District Court · Northern District of California
- 4
In Stiles v. Kahn, Judge Seeborg dismissed the action without prejudice for lack of jurisdiction and dismissed the temporary restraining-order motion as moot.
Steven Foster Stiles and the defendants named in the action were affected. The action was dismissed without prejudice without leave to amend, the temporary restraining-order motion was dismissed as moot, and the Clerk was directed to close the case.
What happened
In Stiles v. Kahn, Steven Foster Stiles, who was representing himself, sued at least nine defendants and alleged violations of numerous federal and state laws. He also sought an order temporarily stopping alleged wrongdoing by a defendant and the defendant’s spouse.
The court concluded that the complaint did not establish federal jurisdiction. The allegations did not show the required complete separation of citizenship for a state-law case, and the accusations were too implausible and disconnected to create federal-question jurisdiction.
Judge Seeborg dismissed the action without prejudice, but did not allow Stiles to amend because the court found amendment would be futile. The court also dismissed the temporary restraining-order motion as moot and directed the Clerk to close the case.
The detailed version
- Stiles v. Kahn · No. 3:24-cv-00558
- Richard Seeborg
- Feb. 1, 2024
Background
Steven Foster Stiles, representing himself, filed an action naming at least nine defendants. The complaint alleged violations of “17 Federal Laws and State Laws,” including aggravated kidnapping, violations of the Racketeer Influenced and Corrupt Organizations Act, elder abuse, attempted murder, battery, and false imprisonment. Stiles also sought a temporary restraining order based on allegations that defendant Blaine Truman Lowry and Lowry’s spouse trespassed on Stiles’s property, stole from him, and committed other misconduct.
The case was transferred from the Eastern District of California to the Northern District of California because it concerned property located in the Northern District. Stiles then filed a 560-page amended complaint that added defendants, including universities and pharmaceutical companies. The court stated that the amended complaint named 27 defendants. A footnote also stated that the amended complaint was filed outside the time allowed by Federal Rule of Civil Procedure 15 and without permission from the court or the defendants.
Jurisdiction
The original complaint invoked diversity jurisdiction, which generally requires that no plaintiff be a citizen of the same state as any defendant and that the required amount be in dispute. The court stated that the complaint itself indicated that Stiles and several defendants appeared to be citizens of California, so diversity jurisdiction was unavailable.
The court also considered whether the allegations created federal-question jurisdiction. It stated that the complaint’s allegations were disjointed and that, taken together with the temporary-restraining-order allegations, they appeared frivolous and did not provide a basis for federal-question jurisdiction. The court noted that another federal court had dismissed similar claims asserted by Stiles, including claims involving the Racketeer Influenced and Corrupt Organizations Act, alleged federal crimes, and matters barred under the rule concerning federal review of certain state-court judgments.
Ruling
The court dismissed the action, without prejudice, for lack of subject-matter jurisdiction. It dismissed the action without leave to amend because it found amendment would be futile. The court also dismissed Stiles’s motion for a temporary restraining order as moot and directed the Clerk to close the file.
Classification
This is a procedural order because the court ended the case for lack of subject-matter jurisdiction without deciding whether Stiles’s underlying accusations were legally valid.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.