Patel v. Hamilton Medical Center, Inc., No. 19-13088 (11th Cir. 2020)Annotate this Case
After the Medical Center suspended plaintiff's medical privileges, plaintiff filed suit against the Medical Center, an injunction against the suspension, and a declaration that the Health Care Quality Improvement Act provided no immunity from damages to the Medical Center.
The Eleventh Circuit vacated the district court's judgment and remanded with instructions to dismiss plaintiff's complaint for lack of subject matter jurisdiction. Plaintiff contends only that federal question jurisdiction exists over his suit, but a request for declaratory relief that a federal law does not entitle the opposing party to a defense ordinarily does not raise a federal question under 28 U.S.C.1331. The court explained that, because the Declaratory Judgment Act does not enlarge the court's jurisdiction, plaintiff must still assert an underlying ground for federal court jurisdiction. In this case, plaintiff's complaint does not establish that the Medical Center could file a coercive action under federal law. Furthermore, a plaintiff cannot create federal question jurisdiction by seeking a declaration that a federal defense does not protect the defendant. Therefore, plaintiff's request for declaratory judgment does not establish federal question jurisdiction.