Roberts v. Montefiore Mount Vernon The University Hospital for Albert Einstein…

Background

Jazmine I. Roberts filed the action without a lawyer and was allowed to proceed without paying filing fees in advance. She alleged that she went to Montefiore Mount Vernon The University Hospital for Albert Einstein College of Medicine on February 15 and February 20, 2024, for abdominal pain; was diagnosed with pelvic inflammatory disease; received an examination and stabilization treatment from Dr. Eskee; and was discharged. She said that she could not obtain the prescribed medication because her health-insurance identification numbers were reported as inactive. She also alleged that she was facing discrimination and retaliation because of earlier litigation. She sought money damages.

Subject-Matter Jurisdiction

Subject-matter jurisdiction is the court’s legal authority to hear a case. Roberts invoked federal-question jurisdiction under 28 U.S.C. § 1331, which applies when a claim arises under the Constitution, federal laws, or treaties. The court concluded that her allegations did not show that the defendant violated federal law or a constitutional right. The court also found that her allegation of discrimination and retaliation was not connected by pleaded facts to her earlier litigation or to conduct by the defendant that violated federal law.

The court separately considered diversity jurisdiction under 28 U.S.C. § 1332, which can allow a federal court to hear certain state-law claims when the parties are citizens of different states and more than $75,000 is at stake. The court found that the information in the complaint indicated that Roberts and the defendant were in New York, so the required complete diversity was not shown. The court therefore could not exercise jurisdiction over any state-law claim she might have been asserting.

Disposition

The court dismissed Roberts’s complaint for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3). It denied leave to amend, finding that amendment would be futile because the parties were not diverse and any claims would arise under state law. Judge Laura Taylor Swain also certified that any appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. The court directed the Clerk of Court to enter judgment.