Roberts v. Amtrack Railroad Company

Background

Jazmine Iman Roberts proceeded without a lawyer and sued “Amtrack Railroad Company,” which the court understood to be Amtrak, also known as the National Railroad Passenger Corporation, and Pete Buttigieg, Secretary of Transportation. Roberts alleged that, on September 6, 2023, she went to an Amtrak station in Manhattan to travel to Washington, D.C. After a customer-service issue involving her rewards account, she boarded the train and looked for seating designated for people with disabilities.

Roberts alleged that an employee explained there was a particular price or designation for disability seating. After the employee scanned her ticket, Roberts and the employee had a miscommunication or confrontation about the seating area and qualifications. Their voices were raised, and the employee told Roberts she would be removed at the next stop. When the train reached New Jersey, New Jersey police officials asked her to leave, and she complied. Roberts described psychological abuse and removal from the train after paying $144.90 for a ticket. She sought a ticket refund and compensation for psychological abuse.

Court’s Screening Review

Because Roberts had been allowed to proceed without paying court fees, the court was required to screen the complaint. It had to dismiss claims that were frivolous, failed to state a legally sufficient claim, sought money from an immune defendant, or fell outside the court’s subject-matter jurisdiction. The court also applied the rule that self-represented complaints are read generously but still must provide enough facts to make a claim plausible.

Disability Claims

The court read the complaint as attempting to assert claims under Title II of the Americans with Disabilities Act. To state such a claim, Roberts needed to allege facts showing that she had a qualifying disability, that the defendant was covered by the statute, and that she was denied access to covered services because of her disability.

The court noted that Roberts did not describe the nature of her disability. It also found that, even assuming she had a qualifying disability, it was unclear whether she was denied access to services because of her disability rather than because of the confrontation about seating. The court therefore granted Roberts leave to amend her claims against Amtrak. An amended complaint would need facts suggesting both a qualifying disability and discriminatory intent or ill will because of that disability.

Claims Against Pete Buttigieg

The court understood Roberts to be suing Buttigieg in his official capacity. It held that sovereign immunity generally bars suits against the federal government and federal officers sued in their official capacities unless immunity has been waived.

The court liberally treated the possible damages claims as claims under the Federal Tort Claims Act, which can waive immunity for certain tort claims involving federal employees. But that law generally requires a claimant first to file an administrative claim with the appropriate federal entity and receive a final written decision, or wait six months without one, before filing in federal court. Roberts did not allege that she had completed those steps. The court therefore dismissed her claims against Buttigieg under sovereign immunity and, consequently, for lack of subject-matter jurisdiction.

State-Law Claims and Diversity Jurisdiction

To the extent Roberts intended to bring state-law claims, the court explained that diversity jurisdiction requires the parties to be citizens of different states and the amount in dispute to exceed $75,000. The court stated that Roberts was a resident of New York and that she alleged Amtrak maintained its headquarters in Washington, D.C., which likely established diversity between Roberts and Amtrak. However, the complaint sought a $144.90 ticket refund and an unspecified amount for psychological abuse, and the court could not conclude that the claim was worth more than $75,000.

The court granted Roberts leave to amend any state-law claims. She would need to allege facts showing both different state citizenship and an amount in controversy exceeding $75,000. If the amended complaint did not establish federal jurisdiction or state a federal claim, the court said it would decline to exercise supplemental jurisdiction over any remaining state-law claims.

Disposition

The court granted Roberts 60 days to file an amended complaint asserting additional facts supporting possible ADA claims against Amtrak and state-law claims. The amended complaint would replace, rather than supplement, the original complaint. The court directed Roberts to include the relevant people, events, dates, locations, injuries, and requested relief.

The court dismissed Roberts’s claims against Pete Buttigieg under sovereign immunity and for lack of subject-matter jurisdiction. It did not issue a summons at that time. If Roberts failed to amend within 60 days without showing good cause, the court stated that the complaint would be dismissed for the reasons in the order and that the court would decline supplemental jurisdiction over any state-law claims. The court also certified that an appeal would not be taken in good faith and denied fee-free appeal status.