Brown v. JP Morgan Chase & Co.

Background

D’Amonte Brown, who lived in Manhattan and was representing himself, sued JP Morgan Chase & Co. Brown invoked diversity-of-citizenship jurisdiction, which allows a federal court to hear certain disputes involving citizens of different states when the amount in dispute exceeds $75,000. The court had previously allowed Brown to proceed without paying court fees in advance.

The complaint form did not identify any causes of action or provide facts about the events underlying the lawsuit. Attached materials included Brown’s application for SNAP benefits and invoices he emailed to Chase Chief Executive Officer James Dimon. The invoices demanded $3,872,400, a credit card with a $10,000 limit, and a $45,000 loan.

Jurisdiction

The court explained that federal courts generally have jurisdiction over federal-law claims or qualifying disputes between citizens of different states. Brown’s allegation that he was a New York resident, treated liberally as an allegation of citizenship, and his identification of JP Morgan Chase Bank as the defendant appeared to satisfy the parties’ citizenship requirement. But the complaint gave no facts explaining what state-law claims Brown had, what occurred, why he was entitled to damages, or why there was a reasonable basis for claims exceeding $75,000.

The complaint also did not establish federal-question jurisdiction. Brown did not invoke that basis of jurisdiction, and the complaint contained no specific federal claims or facts showing entitlement to relief under federal law.

Ruling

The court dismissed the complaint for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3). It granted Brown 30 days’ leave to replead his claims in an amended complaint. The amended complaint must replace, rather than supplement, the original complaint and must include the facts and claims Brown wants the court to consider. It must also comply with the rule requiring a short and plain statement showing entitlement to relief and must provide enough facts to support a plausible claim and establish federal jurisdiction.

The court directed Brown to submit the amended complaint to the court’s Pro Se Intake Unit, label it as an amended complaint, and include docket number 23-CV-2775 (LTS). If Brown does not timely file an amended complaint or show cause for not doing so, the court will enter judgment consistent with the order. The court certified that an appeal would not be taken in good faith and denied Brown the ability to proceed without prepaying appeal fees.