Background
D. Miranda Burroughs, proceeding pro se, filed suit against Hampton Roads Transit in the Eastern District of Virginia. The district court granted her application to proceed in forma pauperis but dismissed the action for lack of subject matter jurisdiction. Burroughs appealed to the Fourth Circuit.
The district court found that Burroughs’ complaint raised no federal question under 28 U.S.C. § 1331 and that diversity jurisdiction under 28 U.S.C. § 1332 was likewise unavailable because both Burroughs and Hampton Roads Transit are Virginia citizens. The court accordingly dismissed the case without reaching the merits.
The Court’s Holding
A per curiam panel of the Fourth Circuit affirmed the district court’s dismissal. Reviewing the complaint, the court confirmed that Burroughs raised no claim arising under the Constitution, laws, or treaties of the United States, foreclosing federal question jurisdiction under 28 U.S.C. § 1331. Because both parties are Virginia citizens, complete diversity was absent and diversity jurisdiction under 28 U.S.C. § 1332 did not exist either.
The court found no error in the district court’s analysis and affirmed the dismissal. Oral argument was dispensed with as unnecessary given the straightforward nature of the jurisdictional issues.
Key Takeaways
- A federal court must dismiss a case where neither federal question nor diversity jurisdiction exists, regardless of the merits of the underlying claim.
- Diversity jurisdiction requires complete diversity — both parties being citizens of different states — and an amount in controversy exceeding $75,000; shared state citizenship between plaintiff and defendant defeats it entirely.
- A pro se plaintiff’s in forma pauperis status does not save a complaint from dismissal for lack of subject matter jurisdiction.
Why It Matters
This unpublished decision is a straightforward application of foundational federal jurisdiction principles under 28 U.S.C. §§ 1331 and 1332. It serves as a reminder that federal courts are courts of limited jurisdiction — a plaintiff must independently establish either a federal question or complete diversity before a federal tribunal can hear the case on the merits.
For practitioners advising clients who lack a federal statutory hook and share state citizenship with a defendant, this case underscores the importance of evaluating forum selection at the outset, as filing in federal court under those circumstances will result in dismissal before any substantive review occurs.