“it is the responsibility of a court to make an independent evaluation of whether subject matter jurisdiction exists in every case”
How later courts described this case
- “it is the responsibility of a court to make an independent evaluation of whether subject matter jurisdiction exists in every case”
Written by the judges who cited it.
The opinion
IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF ILLINOIS
MATTHEW S. WOODS, )
)
Plaintiff, )
)
vs. ) Case No. 22-CV-2933-SMY
)
MARUCHAN, INC., )
)
Defendant. )
)
MEMORANDUM AND ORDER
YANDLE, District Judge:
Pending before the Court are Plaintiff Matthew S. Woods’ Motion for Leave to Proceed in
forma pauperis (Doc. 4), Motion for Service of Process at Government Expense (Doc. 5), and
Motion for Recruitment of Counsel (Doc. 6).
Under 28 U.S.C. § 1915, an indigent party may commence a federal court action without
paying required costs and fees upon submission of an affidavit asserting the inability “to pay such
fees or give security therefor” and stating, “the nature of the action, defense or appeal and the
affiant’s belief that the person is entitled to redress.” 28 U.S.C. § 1915(a)(1). The Court is
satisfied from Woods’ jail records that he is indigent and cannot pay the $400.00 filing fee at this
time (Doc. 4).
Additionally, 28 U.S.C. § 1915(e)(2) requires careful threshold scrutiny of a Complaint
filed by a plaintiff seeking to proceed IFP. The Court may dismiss a case if it determines the action
is clearly frivolous or malicious, fails to state a claim, or is a claim for money damages against an
immune defendant. 28 U.S.C. § 1915(e)(2)(B); see also Hoskins v. Poelstra, 320 F.3d 761, 763
(7th Cir. 2003). This Court will also examine sua sponte the issue of federal subject matter
jurisdiction. See, Foster v. Hill, 497 F.3d 695, 696-697 (7th Cir. 2007) (“it is the responsibility of
a court to make an independent evaluation of whether subject matter jurisdiction exists in every
case”).
Woods is an inmate at the Marion County Jail and an Illinois resident (Doc. 3, p. 4).
Maruchan, Inc. is a California-based manufacturer, allegedly incorporated in the state of
California, that produces ramen noodle soup (Doc. 3, p. 5). Woods alleges that in an effort to lose
weight, he reviewed the nutritional facts on packages of Maruchan ramen noodle, determined that
its caloric value could help him lose weight, and made it the “number one item [he] spent [his]
money on” while in jail (Doc. 3, pp. 5-6). He further alleges that he gained weight because the
amount of the calories was “false and misleading and does not add up to the propper [sic] amount
of calories per container” (Doc. 3, p. 6). He asserts a violation of the California False Advertising
Law and seeks $10,000 in damages (Doc. 3, pp. 4-5).
Federal Courts have original jurisdiction over civil actions if there is complete diversity
between the parties and the amount in controversy exceeds $75,000, exclusive of interest and costs.
28 U.S.C. § 1332. Plaintiff, as the proponent of federal subject matter jurisdiction in this case,
bears the burden of proof as to its existence. Meridian Sec. Ins. Co. v. Sadowski, 441 F.3d 536,
540 (7th Cir. 2006).
Even assuming that there was complete geographic diversity between Woods and
Maruchan, Inc., Woods seeks damages of only “$10,000” (Doc. 3, p. 5).1 Given that the “sum
claimed by the plaintiff controls” if made in good faith, the amount in controversy does not exceed
1 Alternatively, Mr. Woods checks the box for “federal question” jurisdiction (Doc. 3, p. 4). To establish
federal question jurisdiction, Mr. Woods must show either: (1) that a federal statute grants the court
jurisdiction; or (2) that there is common law jurisdiction to a “uniquely federal interest,” which would be
frustrated by the “application of state law.” Northrop Corp. v. AIL Systems, Inc., 959 F.2d 1424, 1426-27
(7th Cir. 1992). Mr. Woods cannot establish federal jurisdiction because he is proceeding on a California
state statute and cannot demonstrate that there is a uniquely federal interest in this litigation.
$75,000. Thus, Woods cannot establish federal diversity jurisdiction. Saint Paul Mercury Indem.
Co. v. Red Cab Co., 303 U.S. 283, 288 (1938).
For the foregoing reasons, Plaintiff's Motion for Leave to Proceed in forma pauperis (Doc.
4) is DENIED and the Complaint (Doc. 3) is DISMISSED without prejudice for lack of subject
matter jurisdiction. All pending motions are TERMINATED as MOOT and the Clerk of Court
is DIRECTED to close the case.
IT IS SO ORDERED. New Ke Cell
DATED: January 9, 2023
STACI M. YANDLE
United States District Judge
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