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Vaughn v. Jacksonville State University

United States District Court, N.D. Alabama, Eastern Division

July 24, 2015

JACKSONVILLE STATE UNIVERSITY, WILLIAM A. MEEHAN, President, in his Official Capacity; JOE G. DELAP, Vice Provost and Dean of Graduate Studies, in his Official Capacity; REBECCA O. TURNER, Provost, in her Official Capacity; and TIMOTHY B. KING, Title IX Coordinator, in his Official Capacity, Defendants.



I. Introduction

Plaintiff Rebecca Vaughn ("Ms. Vaughn") initiated this Title IX and Equal Protection/§ 1983 lawsuit against Defendants Jacksonville State University ("JSU"), William A. Meehan, Joe G. Delap, Rebecca O. Turner, and Timothy B. King on May 20, 2015.[1] (Doc. 1). Pending before the court is Defendants' Motion to Dismiss (Doc. 6) (the "Motion") filed on June 19, 2014, pursuant to Rules 12(b)(1) and 12(b)(6) of the Federal Rules of Civil Procedure. On this same date, Defendants filed their supporting brief. (Doc. 7).

Ms. Vaughn filed her opposition (Doc. 12) to the Motion on July 14, 2015. On July 20, 2015, Defendants followed with their reply. (Doc. 13). Accordingly, the Motion is now under submission, and, for the reasons explained below, is GRANTED IN PART, DENIED IN PART, and otherwise TERMED as MOOT.

II. Standard(s)

A. Rule 12(b)(1) Generally

Unlike state courts, federal tribunals are bodies of limited jurisdiction, meaning that the grounds for the court's jurisdiction over the claims asserted by the plaintiff must be present at the time the complaint is filed and must be obvious on the face of the complaint. Fed.R.Civ.P. 8(a); 28 U.S.C. § 1330, et seq. The law is clear that Ms. Smith, the person seeking to invoke federal jurisdiction in this case, has the burden to demonstrate that the court has subject matter jurisdiction. See McNutt v. General Motors Acceptance Corp., 298 U.S. 178, 189, 56 S.Ct. 780, 785, 80 L.Ed. 1135 (1936) ("They are conditions which must be met by the party who seeks the exercise of jurisdiction in his favor.... [and a]s he is seeking relief subject to this supervision, it follows that he must carry throughout the litigation the burden of showing that he is properly in court.").

Further, lack of subject matter jurisdiction cannot be waived or expanded by judicial interpretation, and a jurisdictional deficiency can be raised at any time by either the parties or the court. See, e.g., Am. Fire & Cas. Co. v. Finn, 341 U.S. 6, 17-18, 71 S.Ct. 534, 542, 95 L.Ed. 702 (1951) ("The jurisdiction of the federal courts is carefully guarded against expansion by judicial interpretation or by prior action or consent of the parties."); Sosna v. Iowa, 419 U.S. 393, 398, 95 S.Ct. 553, 557, 42 L.Ed.2d 532 (1975) ("While the parties may be permitted to waive nonjurisdictional defects, they may not by stipulation invoke the judicial power of the United States in litigation which does not present an actual case or controversy, ' and... we feel obliged to address the question of mootness before reaching the merits of appellant's claim.") (citation omitted).

1. Standing

"[S]tanding is a threshold jurisdictional question which must be addressed prior to and independent of the merits of a party's claims.'" Bochese v. Town of Ponce Inlet, 405 F.3d 964, 974 (11th Cir. 2005) (citations omitted). "In essence the question of standing is whether the litigant is entitled to have the court decide the merits of the dispute or of particular issues.'" Bochese, 405 F.3d at 974 (quoting Midrash Sephardi, Inc. v. Town of Surfside, 366 F.3d 1214, 1223 (11th Cir. 2004) (in turn quoting Warth v. Seldin, 422 U.S. 490, 498, 95 S.Ct. 2197, 45 L.Ed.2d 343 (1975))). "Standing is a doctrine that stems directly from Article III's "case or controversy" requirement, ' and thus it implicates our subject matter jurisdiction.'" Bochese, 405 F.3d at 974 (quoting Nat'l Parks Conservation Ass'n v. Norton, 324 F.3d 1229, 1242 (11th Cir. 2003) (in turn citing Vermont Agency of Natural Res. v. United States ex rel. Stevens, 529 U.S. 765, 771, 120 S.Ct. 1858, 1861-62, 146 L.Ed.2d 836 (2000))). "In fact, standing is perhaps the most important' jurisdictional doctrine, and, as with any jurisdictional requisite, [the court is] powerless to hear a case when it is lacking." Bochese, 405 F.3d at 974 (quoting Bischoff v. Osceola County, 222 F.3d 874, 877-78 (11th Cir. 2000) (in turn quoting United States v. Hays, 515 U.S. 737, 742, 115 S.Ct. 2431, 2435, 132 L.Ed.2d 635 (1995))).

2. Mootness

As the Eleventh Circuit has explained the doctrine of mootness:

It is well settled that at the time a plaintiff brings suit he must have standing to prosecute his claim; he must have a "personal stake" in the outcome of the litigation. See, e.g., City of Los Angeles v. Lyons, 461 U.S. 95, 101, 103 S.Ct. 1660, 1665, 75 L.Ed.2d 675 (1983); United States Parole Comm'n v. Geraghty, 445 U.S. 388, 396-97, 100 S.Ct. 1202, 1208-09, 63 L.Ed.2d 479 (1980). The mootness doctrine requires that the plaintiff's controversy remain live throughout the litigation; once the controversy ceases to exist, the court must dismiss the cause for want of jurisdiction. See, e.g., Aetna Life Ins. Co. v. Haworth, 300 U.S. 227, 239-40, 57 S.Ct. 461, 463-64, 81 L.Ed. 617 (1937); Church of Scientology Flag Serv. Org. v. City of Clearwater, 777 F.2d 598, 604 (11th Cir. 1985), cert. denied, 476 U.S. 1116, 106 S.Ct. 1973, 90 L.Ed.2d 656 (1986).... If the plaintiff's claim is not live, the court lacks a justiciable controversy and must dismiss the claim as moot. See Geraghty, 445 U.S. at 404 & n.11, 100 S.Ct. at 1213 & n.11.

Tucker v. Phyfer, 819 F.2d 1030, 1033 (11th Cir. 1987); see also Castorela v. Mellon, 754 F.Supp. 191, 192 (M.D. Fla. 1990) ("The mootness doctrine requires that a live controversy must exist at the case beginning of the ...

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