Strict Federal Rules of Civil Procedure Kill Lawsuit Against Dillard University

Knowing and adhering to the Rules of Civil Procedure in bringing a lawsuit cannot be understated in its importance. Before a lawsuit makes it to court, various steps and procedures must be followed for the case to proceed. Chief among these pre-trial requirements is establishing that the court has the power to decide the present case, otherwise known as the court’s jurisdiction over the case. If a court lacks judicial control over a party to the case or the subject matter involved, the case should not proceed, and the court cannot hand down a valid, binding judgment.

In a lawsuit alleging sexual harassment, assault, mental and physical abuse, perjury, and character defamation, Tyniski Evans represented herself against Dillard University (Dillard). Dillard responded to Evans’s complaint by moving for dismissal for lack of federal subject matter jurisdiction and failure to state a claim upon which the court may grant relief. See Fed.Civ. P. 12(b)(1), (6). The district court granted Dillard’s motion to dismiss for lack of subject matter jurisdiction and dismissed without prejudice, permitting Evans to bring the case again. 

Evans appealed this dismissal, arguing the court had federal subject matter jurisdiction due to Evans receiving financial aid from the Department of Education. The appellate court affirmed the dismissal by the district court, finding that Evans’s complaint did not sufficiently show that the federal court had the power to adjudicate her lawsuit. 

The Federal Rules of Civil Procedure lay out numerous rules and regulations for the permissibility of federal court cases, primarily to preserve the limited judicial resources of the national court system. One of the primary barriers to federal court adjudication is subject matter jurisdiction. Subject matter jurisdiction in the federal court system can exist under diversity jurisdiction or federal question jurisdiction. 

For a federal court to have diversity jurisdiction over a case, the parties involved must be of different state citizenships, and a certain at-issue dollar amount must exist. In Evans’s case, Evans and Dillard are both citizens of Louisiana–therefore, diversity jurisdiction does not exist. 

Federal question jurisdiction must involve a question of federal law, some Constitutional violation perhaps. Evans’s lawsuit did not adequately allege any issue or violation of federal law. Though she asserts that federal question jurisdiction exists because she is a recipient of federal financial aid, that is not sufficient to establish federal question jurisdiction. The federal court could not ultimately hear Evans’ case.

The law is a puzzle, and finding a capable and well-equipped team to represent you is essential to having your case heard and decided by a court. To bring a lawsuit in federal court, Evans has to sufficiently show that the federal court has jurisdiction over the matter. As described above, Evans did not meet such a requirement, so the court denied her claim twice. Therefore, retaining intelligent, effective counsel is paramount to an effective litigation endeavor when you have a legal issue you wish to explore in court.

Additional Sources: Evans v. Dillard 

Written by Berniard Law Firm Blog Writer: Callie Ericksen

Additional Berniard Law Firm Article on Civil Procedure: Fax Filing A Lawsuit, Make Sure You Follow the Rules Precisely