Maddox v. Zera

Background

In 2016, Dr. Richard Zera performed a procedure on Angela Maddox’s left breast. Maddox alleged that she consented to an incision and drainage but that, after she awoke, she learned that Zera had also performed a biopsy and removed the milk duct, part of the nipple, and part of the areola.

Maddox previously sued in Minnesota state court. The state district court concluded that Hennepin County Medical Center and Zera had not been properly served and granted them summary judgment after dismissing Maddox’s claims against the other defendants. The Minnesota Court of Appeals later dismissed Maddox’s appeal for procedural deficiencies, including failure to properly serve notice of the appeal, and the Minnesota Supreme Court denied review.

Maddox then filed this federal complaint against Dr. Zera, Jennifer Hauff, Juliet Tatsumi, HCMC Hospital, and Hennepin Faculty Associates. She asserted six claims under 42 U.S.C. § 1983—including assault, battery, lack of informed consent, breach of contract, intentional infliction of emotional distress, and intent to cause bodily harm—and four claims under 28 U.S.C. § 2680, including abuse of process, misrepresentation, deceit, and interference with letters or postal matter. She also asked the federal court to review the state-court rulings. Maddox represented herself.

Analysis

Magistrate Judge Hildy Bowbeer recommended dismissing the complaint without prejudice for lack of subject-matter jurisdiction and denying Maddox’s application to proceed without prepaying fees as moot. Maddox objected. Judge Tunheim reviewed the objections under the standards governing objections to a magistrate judge’s report and recommendation.

The court applied the Rooker-Feldman doctrine, which generally prevents a federal district court from reviewing and rejecting a state-court judgment. The court held that Maddox’s objections asking it to decide whether the state court had wrongly dismissed her case, ruled on service, addressed informed consent, or failed to enter a default judgment were requests for review of the state proceedings and therefore could not be heard in federal district court.

The court also held that Maddox’s § 1983 claims did not establish federal jurisdiction. Section 1983 provides a civil claim for violations of federal constitutional or statutory rights by someone acting under state or local authority. The court concluded that Maddox’s claims alleged only state-law causes of action. It further stated that receiving federal funding was not enough to show that the defendants acted under state authority for purposes of § 1983.

The court held that Maddox’s claims under § 2680 also did not establish jurisdiction. The court explained that this provision is part of the Federal Tort Claims Act and identifies claims that cannot be brought under that Act; it does not provide relief for the injuries Maddox alleged. Because the court had no original federal jurisdiction over any claim, it also could not exercise supplemental jurisdiction over related state-law claims.

Disposition

Judge Tunheim overruled Maddox’s objections, adopted the Report and Recommendation, and dismissed Maddox’s complaint without prejudice under Federal Rule of Civil Procedure 12(h)(3) for lack of subject-matter jurisdiction. The court explained that dismissal without prejudice allowed the complaint to be refiled, but a proper jurisdictional basis would have to be alleged for the matter to proceed in federal court. The court denied Maddox’s application to proceed without prepaying fees or costs as moot.