Bracken v. Matgouranis
296 F.3d 160, 2002 WL 1496428 (2002)
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Rule of Law:
Under the well-pleaded complaint rule, federal question jurisdiction exists only when a federal question is presented on the face of the plaintiff's properly pleaded complaint, not when the complaint anticipates a defense and asserts that the defense is invalidated by a provision of the Constitution.
Facts:
- Martin Matgouranis allegedly beat and shot his employee and lover, Cheryl Ann Bracken.
- Bracken survived and underwent reconstructive facial surgery.
- On Bracken's behalf, her attorney, H. David Rothman, sent letters to Martin's attorneys requesting financial support for Bracken during her convalescence.
- The letters stated that Bracken would inform the sentencing judge in any criminal proceeding of Martin's compassion, or lack thereof, based on his response.
- Bracken subsequently filed a state court action to discover and freeze Martin's assets.
- During a deposition in that case, William J. Wyrick, attorney for Martin's wife Panorea Matgouranis, accused Bracken and Rothman of attempting to extort money from Martin.
- Bracken and Rothman then filed a defamation lawsuit against Wyrick in Pennsylvania state court.
Procedural Posture:
- Cheryl Ann Bracken and H. David Rothman filed a lawsuit for defamation against William J. Wyrick in the Allegheny County, Pennsylvania, Court of Common Pleas, a state trial court.
- In their complaint, the plaintiffs anticipated a state-law defense of absolute privilege and argued that such a defense would violate their First Amendment rights.
- Based on the federal issue raised in the complaint, the defendants removed the case to the United States District Court for the Western District of Pennsylvania.
- The plaintiffs filed a motion to remand the case back to state court for lack of federal subject matter jurisdiction.
- The District Court denied the plaintiffs' motion to remand, finding that they had raised federal constitutional issues.
- The District Court subsequently granted the defendants' motion to dismiss the plaintiffs' case.
- The plaintiffs appealed to the United States Court of Appeals for the Third Circuit.
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Issue:
Does a federal court have subject matter jurisdiction over state-law claims when the plaintiff's complaint anticipates a state-law defense and asserts that the defense would violate the U.S. Constitution?
Opinions:
Majority - Rosenn, Circuit Judge.
No. Federal question jurisdiction cannot be based on a plaintiff anticipating a defense and pleading a federal constitutional response to it. The court's jurisdiction is determined by the 'well-pleaded complaint rule,' established in Louisville & Nashville Railroad Co. v. Mottley, which requires that a federal question must be an essential element of the plaintiff's own cause of action. It is not sufficient for the plaintiff to allege an anticipated defense and assert that the defense is invalid under the U.S. Constitution. Here, the plaintiffs' claims for defamation sound entirely in Pennsylvania state law. The reference to the First Amendment was not part of their cause of action but was instead a reply to a potential state-law defense of absolute privilege. This is even one step further removed from federal jurisdiction than Mottley, where the anticipated defense was based on a federal statute. Speculation on a state defense and a constitutional answer to it cannot be the basis for federal question jurisdiction.
Analysis:
This case serves as a straightforward application and powerful reaffirmation of the century-old 'well-pleaded complaint rule' from Mottley. It clarifies that the rule applies not only when a plaintiff anticipates a federal defense, but also when a plaintiff anticipates a state-law defense and raises a federal constitutional argument against it. The decision underscores the principle that plaintiffs are the masters of their complaint and can choose to avoid federal court by pleading only state-law claims. This reinforces a bright-line rule for federal question jurisdiction, preventing federal courts from being flooded with cases where federal issues are merely tangential or speculative.
