PHILADELPHIA – A plaintiff who sued a Chevrolet car dealership and its owner over allegedly unfair arbitration and court proceedings, and who had that same complaint dismissed from a federal court for lack of jurisdiction, reached that same result in a federal appellate court.
U.S. Court of Appeals for the Third Circuit judges Patty Shwartz, Cheryl Ann Krause and Julio M. Fuentes issued a per curiam ruling on Aug. 15 throwing out plaintiff Stanley E. Kornafel’s appeal against defendants Del Chevrolet and its owner Jack Del Vecchio, upholding the same result reached in the U.S. District Court for the Eastern District of Pennsylvania.
“Federal courts are courts of limited jurisdiction. They possess only that power authorized by Constitution and statute. Kornafel argues in his appellate brief that the District Court failed to consider the merits of his arguments – but it was without the authority to do so,” the appellate judicial panel said.
“As the District Court properly noted, federal courts do not have subject-matter jurisdiction over claims when ‘(1) The federal plaintiff lost in state court; (2) The plaintiff ‘complains of injuries caused by the state-court judgments’; (3) Those judgments were rendered before the federal suit was filed; and (4) The plaintiff is inviting the district court to review and reject the state judgments.’ While Kornafel’s complaint is not easy to understand, most of the document raises claims about being harmed by state court judgments or arbitration decisions.”
The Third Circuit said it agreed that to the extent that Kornafel’s lawsuit could be broadly construed to raise constitutional claims, such claims were not valid because the only defendants named in the complaint were Del Chevrolet and Jack Del Vecchio, who are not state officials. While a private party may qualify as a state actor if “he or she conspires with a state official”, the appellate court stated Kornafel “has not meaningfully claimed that Del Vecchio has done so.”
“We discern no other basis for jurisdiction in the District Court. Kornafel cited some federal statutes in his complaint, but none of them provides a cause of action for the claims of his complaint. Thus, the District Court did not have federal question jurisdiction,” the Third Circuit concluded.
“And there was no diversity of citizenship, so the District Court lacked diversity jurisdiction. The District Court thus properly dismissed the complaint for lack of jurisdiction. For the foregoing reasons, we will affirm the District Court’s judgment.”
U.S. Court of Appeals for the Third Circuit case 18-2026
U.S. District Court for the Eastern District of Pennsylvania case 2:18-cv-01419
From the Pennsylvania Record: Reach Courts Reporter Nicholas Malfitano at nickpennrecord@gmail.com