Background
The plaintiff appealed a district court dismissal of his suit for lack of jurisdiction. He sought to vacate a judgment from an arbitration proceeding, alleging due process violations. He also raised a claim under Section nineteen eighty-three of Title forty-two of the United States Code.
The court’s reasoning
The court affirmed that the district court correctly concluded it lacked federal question jurisdiction because the plaintiff did not allege any state action. The court noted that a person is deemed a state actor only if they are a state official or act in close correspondence with state officials. The plaintiff did not assert a claim against the State of California or an arm of the State, and the defendant was neither a state official nor working in tandem with the State. The court also affirmed the lack of diversity jurisdiction because the complaint stated both parties were California residents at the time of filing. The court held that it cannot go beyond the face of the complaint to impute allegations that contradict the complaint, even if the plaintiff later claimed the defendant relocated.
What it means going forward
The ruling reinforces that plaintiffs must explicitly plead state action in Section nineteen eighty-three claims and establish diverse citizenship at the time of filing to invoke federal jurisdiction.