Crawford v. School Board For Richmond City et al, No. 3:2020cv00923 - Document 22 (E.D. Va. 2021)

Court Description: OPINION. It is so ORDERED. Signed by District Judge John A. Gibney, Jr. on 05/12/2021. Copy mailed to Plaintiff. (walk, )

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Crawford v. School Board For Richmond City et al Doc. 22 Dockets.Justia.com III. ANALYSIS The Court,construing Crawford's complaint liberally,finds that she asserts claims under the ADA, Section 504 of the Rehabilitation Act of 1973, the IDEA, and the Fourteenth Amendment. The defendant moves to dismiss Crawford's claims on two grounds: (1) lack of subject matter jurisdiction and (2) failure to state a claim. A. Subject Matter Jurisdiction The defendants argue that this Court lacks subject matter jurisdiction over Crawford's complaint for two reasons. First,although Crawford "couches her claim" as a § 1983 suit,"her claim is nothing more than a reprise of [a] ... common law contract claim" that presents no federal question for this Court to decide. (ECF No. 10,at 8.) And because Crawford does not allege diversity of citizenship,this Court lacks subject matter jurisdiction. The defendants also argue that the Rooker-Feldman doctrine bars Crawford's complaint. As for the first argument,although Crawford's gripes arise from a contract dispute,her complaint alleges that the defendants retaliated against her by filing a motion for sanctions in violation of the U.S. Constitution and various federal laws. Cf Custer v. Sweeney, 89 F.3d 1156, 1165 (4th Cir. 1996) ('"[L]ook no farther than the plaintiffs complaint in determining whether a lawsuit raises issues of federal law capable of creating federal-question jurisdiction under 28 U.S.C. § 1331."). Although the Court will dismiss her complaint,it will do so because Crawford's complaint fails to state a claim,not because the Court lacks jurisdiction over the dispute. Regarding the defendants' second argument,the Rooker-Feldman doctrine bars a federal court from having jurisdiction over claims that "were either actually adjudicated by the state court or were otherwise inextricably intertwined with the issues in the state judicial proceeding." Oliver v. Va. Bd. ofBarExam'rs, 312 F. Supp. 3d 515,525 (E.D. Va. 2018). 5 "A federal claim is

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