Hall v. United States of America

Background

Anthony Winston Hall, proceeding without a lawyer, sued the United States of America doing business as the Social Security Administration, the Department of Justice, Deputy Secretary Victoria Shateyman in her official capacity, and other defendants. The complaint contained allegations the court described as not comprehensible, but the court identified one discernible request: an order requiring production of the Numident record associated with Hall’s Social Security number ending in 5575.

Hall alleged that he requested the record in March 2022 and sent additional mailings to the Social Security Administration in April and May 2022. The defendants moved to dismiss under Rules 8, 12(b)(1), and 12(b)(6) of the Federal Rules of Civil Procedure. Hall did not respond after the court gave him an opportunity to do so. The defendants submitted a declaration stating that the Social Security Administration had provided and mailed him a certified copy of the Numident record on December 22, 2022.

Court’s analysis

The court first considered the motion under Rule 12(b)(1), which concerns the court’s subject-matter jurisdiction, meaning its legal authority to hear the case. A case becomes moot when there is no longer a live dispute. When a case is moot, a federal court lacks subject-matter jurisdiction and must dismiss the action.

The court concluded that the defendants had already provided the only relief Hall was discernibly seeking. Because the requested Numident record had been provided, there was no longer a live controversy requiring a court order. The court therefore dismissed for lack of subject-matter jurisdiction and did not reach the defendants’ Rule 8 or Rule 12(b)(6) arguments.

Disposition

The complaint was dismissed without prejudice under Rule 12(b)(1) because the case was moot. The Clerk was directed to close all pending motions and close the case. The court also directed that a copy of the decision be mailed to Hall and that service be noted on the docket.