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Taylor v. Medical Data Systems, Inc.

United States District Court, E.D. Virginia, Richmond Division

July 13, 2017

NICOLE TAYLOR, Plaintiff,
v.
MEDICAL DATA SYSTEMS, INC., Defendant.

          MEMORANDUM OPINION (DISMISSING CASE FOR LACK OF SUBJECT-MATTER JURISDICTION)

          Henry E. Hudson United States District Judge.

         THIS MATTER is before the Court on its own initiative. Plaintiff Nicole Taylor ("Plaintiff) brings this action alleging violations of the Fair Debt Collections Practices Act ("FDCPA"), 15U.S.C. § 1692, et seq. (ECF No. 1.) Defendant Medical Data Systems, Inc. ("Defendant") filed its Answer on June 20, 2017. (ECF No. 3.)

         Because the Court had concerns about whether Plaintiff had sufficiently pleaded an injury in fact to confer standing in this case, it ordered the parties to submit memoranda addressing this issue. (ECF No. 6.) Both parties complied with the Order and have filed briefs supporting their respective positions. (ECF Nos. 8, 9.)

         The Court will dispense with oral argument because the facts and legal contentions are adequately presented in the materials before it, and oral argument would not materially aid in the decisional process. E.D. Va. Local Civ. R. 7(J).

         For the reasons stated herein, the Court finds that it lacks subject-matter jurisdiction and, therefore, must dismiss Plaintiffs Complaint without prejudice.

         I. BACKGROUND

         Plaintiff begins her one-count Complaint by asserting that "[o]n information and belief, on a date better known to Defendant, Defendant began collection activities on an alleged consumer debt from the Plaintiff." (Compl. ¶ 7.) The Complaint notes that this alleged debt was incurred as a financial obligation that was primarily for personal, family or household purposes, and that Southside Regional Medical Center was the original creditor. (Id. ¶¶ 8-9.) Though it is unclear when, at some point Defendant reported the debt on Plaintiffs credit report. (Id. ¶ 11.)

         Plaintiff alleges that she sent a letter to Defendant on November 17, 2016, disputing the debt. (Id. ¶ 12.) Approximately two months later, on January 24, 2017, Plaintiff examined her credit report and found that Defendant had re-reported the debt, but had not listed it as being "disputed by consumer." (Id. ¶ 13.) As a result, Plaintiff summarily alleges that she "has been damaged" and that she "is entitled to damages in accordance with the FDCPA." (Id. ¶¶ 14, 17.)

         However, at no point in his Complaint does Plaintiff specify how she has allegedly been damaged.[1]

         II. LEGAL STANDARD

         Structurally, our Constitution divides the Federal Government into three discrete branches, each with specifically defined powers. As such, it is well settled that judicial power is limited to the extent that federal courts may exercise jurisdiction only over "cases" and "controversies." U.S. Const., art. Ill. § 2; Lujan v. Defenders of Wildlife, 504 U.S. 555, 559 (1992). Thus, subject-matter jurisdiction requires a justiciable case or controversy within the meaning of Article III of the United States Constitution. See Allen v. Wright, 468 U.S. 737, 750-51 (1984), abrogated on other grounds by Lexmark Int'l, Inc. v. Static Control Components, Inc., 134 S.Ct. 1377 (2014). Standing constitutes one component of justiciability. Lujan, 504 U.S. at 560. Whether a plaintiff has standing presents a "threshold question in every federal case, determining the power of the court to entertain the suit." Warth v. Seldin, 422 U.S. 490, 498 (1975). "The objection that a federal court lacks subject-matter jurisdiction may be raised by a party, or by a court on its own initiative, at any stage in the litigation." Arbaugh v. Y&H Corp., 546 U.S. 500, 506 (2006) (internal citation omitted).

         The Supreme Court has established that the "irreducible constitutional minimum" of standing includes three elements: (1) an injury-in-fact; (2) a causal connection between the injury and the alleged misconduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Lujan, 504 U.S. at 560-61 (citations and quotation marks omitted). Because Plaintiff seeks to invoke this Court's jurisdiction, she bears the burden of establishing all three elements. Id. at 561. "Where, as here, a case is at the pleading stage, the plaintiff must 'clearly ... allege facts demonstrating' each element." Spokeo, Inc. v. Robins, 136 S.Ct. 1540, 1547 (2016) (quoting Warth, 422 U.S. at 518).

         In Spokeo, the Supreme Court reiterated the basic tenets of the standing doctrine. Id. at 1547. It noted that to satisfy the injury-in-fact requirement, a plaintiff must show "'an invasion of a legally protected interest' that is 'concrete and particularized' and 'actual and imminent, not conjectural or hypothetical.'" Id. at 1548 (citing Lujan, 504 U.S. at 560).

         To satisfy the particularization requirement, the plaintiff "must allege a distinct and palpable injury to himself." Worth, 422 U.S. at 501 (citations omitted). The injury must "affect the plaintiff in a personal and individual way." Lujan, 504 U.S. at 560 n.l. Claims asserting '"generalized grievance[s]' shared in substantially equal measure by all or a large class of citizens ... normally do[ ] ...


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