Hill v. Maffucci Moving and Storage
- Lorna Schofield
- 1:21-cv-08746
- U.S. District Court · Southern District of New York
- 2
In Hill v. Maffucci Moving and Storage, Judge Schofield ordered plaintiffs to explain federal jurisdiction before possible dismissal.
The plaintiffs, who were proceeding without lawyers, must explain the basis for federal jurisdiction by December 23, 2021, or the case may be dismissed for lack of subject-matter jurisdiction.
What happened
In Hill v. Maffucci Moving and Storage, plaintiffs representing themselves alleged violations of the Americans with Disabilities Act and the New York City Human Rights Law. Their federal claim was based on travel to Suffolk County for proceedings in an earlier state-court case.
The court questioned whether it had authority to hear the case. It said the disability claim did not present a valid federal question and that diversity jurisdiction was unavailable because the plaintiffs and Maffucci Moving and Storage were all connected to New York for jurisdictional purposes.
Judge Lorna G. Schofield ordered the plaintiffs to file a letter by December 23, 2021, identifying any legal basis for federal jurisdiction and explaining why the case should not be dismissed for lack of jurisdiction. The order did not itself dismiss the case.
The detailed version
- Hill v. Maffucci Moving and Storage · No. 1:21-cv-08746
- Lorna Schofield
- Dec. 2, 2021
Background
Plaintiffs filed the complaint while proceeding without lawyers. They invoked federal-question jurisdiction and diversity jurisdiction and alleged violations of the Americans with Disabilities Act (ADA) and the New York City Human Rights Law. The ADA claim was based on an earlier case that plaintiffs had filed in Suffolk County state court. Plaintiffs alleged that defendants defaulted in that proceeding and that plaintiffs' resulting travel to Suffolk County for court proceedings amounted to disability discrimination under the ADA.
Jurisdictional analysis
The court explained that federal courts must independently determine whether they have subject-matter jurisdiction, meaning legal authority to hear a case. It concluded that the complaint did not state a colorable federal claim. The court held that the allegations about travel to the state-court proceedings did not create federal-question jurisdiction under 28 U.S.C. § 1331.
The court also determined that diversity jurisdiction was unavailable. Diversity jurisdiction generally requires all plaintiffs to be citizens of states different from all defendants, along with the required amount in controversy. The opinion states that the plaintiffs are New York citizens and that Maffucci Moving and Storage is headquartered in New York, so complete diversity was absent.
Order
The court ordered plaintiffs to file, by December 23, 2021, a letter stating any legal basis for concluding that the court has subject-matter jurisdiction and any reason the case should not be dismissed for lack of subject-matter jurisdiction. The order did not dismiss the case at that point.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.