Hatwood v. Sanchez

Background

Annette Hatwood, proceeding without a lawyer, sued Savannah Sanchez. Hatwood alleged that Sanchez stole her identity and property, improperly accessed her devices and network, took money from various accounts, used her credit cards fraudulently, and engaged in cyberstalking. Hatwood alleged that Sanchez had worked for her from July through September 2020, performing errands and contacting clients. Hatwood sought approximately $25,000 and asked to get her “life back.”

Jurisdictional analysis

The court first considered federal-question jurisdiction, which allows a federal court to hear claims arising under federal law. The court concluded that Hatwood’s allegations against a private individual did not indicate a federal claim and appeared to arise solely under state law. Merely invoking federal-question jurisdiction was not enough.

The court then considered diversity jurisdiction, which generally requires complete diversity of citizenship between the parties and more than $75,000 in controversy. The court found that Hatwood had not stated Sanchez’s citizenship. It also found that Hatwood’s request for approximately $25,000 did not satisfy the required amount in controversy. The court therefore determined that it lacked subject-matter jurisdiction, meaning authority to hear the action.

Disposition

The court dismissed the action for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3). It denied leave to amend because it concluded that the defects could not be cured by amendment. The court also certified that any appeal would not be taken in good faith and denied Hatwood fee-free status for purposes of an appeal. The court did not decide whether Sanchez actually committed the alleged conduct or whether Hatwood was otherwise entitled to relief.