Opinion
Civil Action No. 19-1171 (BAH)
04-29-2019
GLOBAL CARPET CLEANING, Plaintiff, v. CATHAL ARMSTRONG, Defendant.
MEMORANDUM OPINION
Global Carpet Cleaning initiated this action on April 23, 2019 to recover for water-damage-remediation services performed for Cathal Armstrong on February 7, 2018. See Compl. at 1, ECF No. 1. After completing those contracted-for services, Global Carpet Cleaning sent Armstrong an invoice for $18,202.92. Id. In April 2018, Armstrong made a $5,000 payment. Id. Armstrong allegedly promised to pay the remaining $13,202.92 by June 1, 2018 but did not do so, which, Global Carpet Cleaning alleges, "has caused serious prejudice to our company and has drastically hindered our ability to evolve as a business, in addition to seriously inflicting emotional distress to us." Id. at 2. As a remedy, the complaint asks the Court "to instruct Armstrong, Cathal to pay the balance of $13,202.92 including 20% interest ($2,640.58) and all the legal costs (court fees and others). The specific amount we are requesting from the defendant at this point in time is $15,843.50." Id.
Federal courts have limited jurisdiction, authorized to hear only "civil actions arising under the Constitution, laws, or treaties of the United States," see 28 U.S.C. § 1331, or "civil actions where the matter in controversy exceeds the sum or value of $75,000" and the suit is between citizens of different states, see id. § 1332. "[A] district court may dismiss a complaint sua sponte prior to service on the defendants pursuant to Fed. R. Civ. P. 12(h)(3) when . . . it is evident that the court lacks subject-matter jurisdiction." Evans v. Suter, No. 09-5242, 2010 WL 1632902, at *1 (D.C. Cir. Apr. 2, 2010).
The complaint here does not state a claim arising under the Constitution or federal law, but rather seek remedies for the defendant's alleged breach of contract. The parties may be diverse—the defendant allegedly is a resident of the District of Columbia and the plaintiff lists a Maryland address. Nevertheless, the amount in controversy is only $15,843.50. Therefore, this suit cannot be brought in federal court.
The plaintiff's citizenship for purposes of diversity is uncertain given that the complaint does not indicate Global Carpet Cleaning's corporate form. --------
Accordingly, the Court will dismiss the complaint for lack of subject matter jurisdiction. An Order consistent with this Memorandum Opinion will be issued contemporaneously.
Date: April 29, 2019
/s/_________
BERYL A. HOWELL
Chief Judge