Bell Bey v. The Mount Sinai Hospital
- Colleen McMahon
- 1:19-cv-09573
- U.S. District Court · Southern District of New York
- 5
Cooleridge Bey Bell v. The Mount Sinai Hospital: Judge McMahon dismissed the case for lack of federal jurisdiction, without prejudice.
Cooleridge Bey Bell's federal action against The Mount Sinai Hospital was dismissed without prejudice because the court lacked subject matter jurisdiction. The order also affects any future similar fee-free filings by warning that prior permission may be required, and it denies fee-free status for an appeal.
What happened
Cooleridge Bey Bell sued The Mount Sinai Hospital over an outstanding bill, claiming he was not the person who owed it. He represented himself and sought several million dollars in damages.
The court found no federal-law claim and no diversity jurisdiction because the complaint indicated that both sides were in New York. The court therefore could not hear the case.
Judge McMahon dismissed the complaint without prejudice for lack of subject matter jurisdiction. She warned that similar future cases could lead to a restriction on filing new cases without paying fees, and denied fee-free status for an appeal.
The detailed version
- Bell Bey v. The Mount Sinai Hospital · No. 1:19-cv-09573
- Colleen McMahon
- Nov. 26, 2019
Background
Cooleridge Bey Bell, representing himself, sued The Mount Sinai Hospital about an outstanding bill. The opinion says that the bill was addressed to Cooleridge Bell, that the address on the bill matched the plaintiff's address, and that the plaintiff claimed he was not the person who owed the debt. He sought several million dollars in damages. The court had previously allowed him to proceed without paying the filing fee.
Jurisdiction
Federal district courts have limited subject matter jurisdiction, meaning they may hear only cases authorized by federal law. The court considered federal-question jurisdiction and diversity jurisdiction. It found no federal-question jurisdiction because the plaintiff's claims did not arise under federal law. It also found no diversity jurisdiction because the complaint indicated that both the plaintiff and The Mount Sinai Hospital were in New York. The court therefore concluded that it could not exercise jurisdiction over the action.
Disposition
The court dismissed the complaint without prejudice for lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3). The court also warned that further similar litigation in the Southern District of New York would result in an order barring the plaintiff from filing new actions without paying fees unless he first obtained permission. The court certified that any appeal would not be taken in good faith and denied the plaintiff permission to proceed without paying fees for an appeal.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.