Reported / Citable
Background
Pro se plaintiff Devin Scott Williams sued Harrell Hospitality Group LLC, seeking damages for an alleged breach of an arbitration agreement. His original complaint did not identify a basis for federal jurisdiction. It sought $50,000 and indicated that both Williams and Harrell were citizens of Texas.
After the magistrate judge raised jurisdiction at an initial pretrial conference, Williams moved to amend. He proposed increasing his damages demand to $100,000 and adding Marriott International, Inc. as a defendant. He argued that diversity jurisdiction and the Federal Arbitration Act supplied federal jurisdiction.
The Court’s Holding
Magistrate Judge Derek T. Gilliland recommended dismissing the action without prejudice for lack of subject-matter jurisdiction. The recommendation is not a final district-court disposition; it was submitted to District Judge Alan D. Albright, and the parties were advised of their opportunity to object.
The Federal Arbitration Act does not independently confer federal jurisdiction, the magistrate judge concluded. Williams therefore needed an independent basis for jurisdiction. Diversity was unavailable because it was undisputed that Williams and Harrell shared state citizenship, defeating complete diversity. The magistrate judge also recommended denying all pending motions as moot.
Key Takeaways
- The Federal Arbitration Act alone does not create federal subject-matter jurisdiction.
- Complete diversity requires that no plaintiff share citizenship with any defendant.
- Adding a new defendant and increasing the requested damages could not cure the jurisdictional defect arising from Williams’s shared citizenship with Harrell.
Why It Matters
The recommendation underscores that a federal court must confirm its jurisdiction even when neither party initially contests it. Parties seeking to litigate arbitration-related contract disputes in federal court must identify an independent federal-question or diversity basis.