Roberts v. Narayan Pharmacy

Background

Jazmine I. Roberts, appearing without a lawyer, sued Narayan Pharmacy under the court’s federal-question jurisdiction. The complaint alleged that, after an appointment was canceled because of weather, Roberts went to Narayan Pharmacy for emergency stabilization and was seen by a nurse practitioner. She alleged that the pharmacy refused to provide her prescription because none of her health-insurance member numbers were active. She also alleged that she was experiencing discrimination and retaliation connected to an earlier docket number. Roberts sought money damages.

The court had previously allowed Roberts to proceed without paying filing fees in advance. In reviewing the complaint, the court was required to dismiss an action filed without those fees if it lacked subject-matter jurisdiction, meaning authority to hear the case.

Federal-Question Jurisdiction

The court ruled that Roberts did not allege facts showing that Narayan Pharmacy violated federal law. Although she invoked federal-question jurisdiction, the complaint did not identify facts establishing a federal-law claim. The court stated that her allegations instead suggested that she could not obtain the medication because the pharmacy did not have insurance information that presumably would have covered the medication’s cost.

The court also addressed Roberts’s reference to prior litigation. It found that she did not allege facts connecting that earlier litigation to Narayan Pharmacy’s decision not to provide the prescription, or explaining how any such connection would violate federal law. The court therefore concluded that the allegations did not show that federal law or a constitutional right was involved.

Diversity Jurisdiction

The court also considered whether it could hear any state-law claim based on diversity jurisdiction. Diversity jurisdiction generally requires the plaintiff and defendant to be citizens of different states, along with the required amount in controversy. The court found that the information in the complaint indicated that Roberts and Narayan Pharmacy were both in New York, which prevented the required complete diversity. The court therefore could not exercise diversity jurisdiction over any state-law claim Roberts might be asserting.

Disposition

The court denied leave to amend because it found that amendment could not cure the jurisdictional defect. It concluded that Roberts’s claims arose under state law, that federal jurisdiction over those claims could exist only through diversity jurisdiction, and that the parties were not diverse.

The court dismissed the complaint for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3). It directed the Clerk of Court to enter judgment. The court also certified that any appeal would not be taken in good faith and denied Roberts’s fee-free status for purposes of an appeal.