Snead v. Maryland Management Company

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
SHARAA SNEAD,
Plaintiff,
v.
MARYLAND MANAGEMENT
COMPANY,
Defendant.
Civil Action No.
1:25-cv-3321-ABA
MEMORANDUM OPINION and ORDER
Self-represented Plaintiff Sharaa Snead filed her complaint on October 6, 2025.
She has also filed a motion to proceed in forma pauperis (ECF No. 2), which will be
granted. Because the complaint only raises landlord-tenant claims, this Court will, on its
own initiative, dismiss the case for lack of subject matter jurisdiction.
Because the case is at the pleading stage, the Court will assume the truth of Ms.
Snead’s allegations. See Episcopal Church in S.C. v. Church Ins. Co. of Vermont, 997
F.3d 149, 154 (4th Cir. 2021). In her complaint, Ms. Snead alleges that employees of
Defendant Maryland Management Company (the property manager of her residence)
knocked on her door and opened it before she had an opportunity to answer. ECF No. 1
at 6. It is unclear from the complaint whether these employees entered Ms. Snead’s
home or merely opened the door. Ms. Snead’s complaint and the attached exhibits
indicate that the employees who opened her door were employed by Defendant to do
maintenance work in response to service requests, ECF No. 1-1 at 5–7, and were at her
apartment in this circumstance to do routine maintenance, ECF No. 1-1 at 12. She asks
the Court for assistance in finding another home and for $75,000. ECF No. 1 at 5, 7.
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Federal courts have limited jurisdiction, “constrained to exercise only the
authority conferred by Article III of the Constitution and affirmatively granted by
federal statute.” In re Bulldog Trucking, Inc. 147 F.3d 347, 352 (4th Cir. 1998).
Accordingly, federal courts have original jurisdiction over civil cases, with some
exceptions that are not relevant here, in only two instances: (1) under federal question
jurisdiction, where the case involves an issue of federal law, see 28 U.S.C. § 1331, or (2)
under diversity jurisdiction where no defendant may be a citizen of the same state as any
plaintiff and the amount in controversy exceeds $75,000, see 28 U.S.C. § 1332. The
Court has “an independent obligation to determine” the existence of subject-matter
jurisdiction, Hertz Corp. v. Friend, 559 U.S. 77, 94 (2010), that “may (or, more
precisely, must) be raised sua sponte.” Brickwood Contractors, Inc. v. Datanet Eng’g,
Inc., 369 F.3d 385, 390 (4th Cir. 2004). “If the court determines at any time that it lacks
subject-matter jurisdiction, the court must dismiss the action.” Fed. R. Civ. P. 12(h)(3).
Ms. Snead contends that federal question jurisdiction applies in this case. ECF
No. 1 at 4. She states that the federal law issue arises from her claim that “maintenance
[and/or] management has to give the tenant reasonable notice before entering their
home.” ECF No. 1 at 4. In other words, Ms. Snead’s claims relate to a landlord-tenant
dispute. But the relationship between a landlord and tenant is a “particular domain of
state law.” Alabama Ass’n of Regulators v. Dep’t of Health and Hum. Servs., 594 U.S.
758, 764 (2021); see also Joy v. Daniels, 479 F.2d 1236, 1243 (4th Cir. 1973) (“Landlord-
tenant law is traditionally the province of the states”). “Such claims arise under
Maryland law and may not be brought in this Court, based on federal question
jurisdiction.” Anpu El v. Walker Mews Apartments, Case No. 21-cv-1504-ELH, 2021
WL 2936280, at *3 (D. Md. July 13, 2021). Ms. Snead does not refer to or cite any
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federal statute or constitutional provision as a basis for jurisdiction. This Court lacks
federal question jurisdiction over Ms. Snead’s claims.
In her complaint, which was filed on the District of Maryland’s standard pro se
form, Ms. Snead checked the box for federal question jurisdiction as the basis for
jurisdiction, but also filled out information in the section of the form for diversity
jurisdiction. ECF No. 1 at 4. To the extent Ms. Snead intended to contend that diversity
jurisdiction applies, the Court does not have jurisdiction on that basis either. District
courts “shall have original jurisdiction of all civil actions where the matter in
controversy exceeds the sum or value of $75,000 . . . between citizens of different
states.” 28 U.S.C. § 1332(a)(1) (emphasis added). The complaint does not allege diversity
of citizenship, but instead states that both parties are residents of Maryland. ECF No. 1
at 2, 4. The Court does not have jurisdiction based on diversity of citizenship in this case
either.
While the Court is mindful of its obligation to liberally construe the pleadings of
self-represented litigants, see Erickson v. Pardus, 551 U.S. 89, 94 (2007), liberal
construction does not mean that this Court may ignore a clear failure to allege a basis for
federal jurisdiction. See Weller v. Dep’t of Soc. Servs., 901 F.2d 387, 391 (4th Cir. 1990).
Even reading the complaint with deference to Ms. Snead, and accepting all of the
allegations in her complaint as true, there is no basis for federal jurisdiction here.
ORDER
For the reasons stated above, the Court hereby ORDERS as follows:
1. 	Plaintiff’s motion to proceed in forma pauperis (ECF No. 2) is GRANTED;
2. 	Plaintiff’s complaint is DISMISSED without prejudice;
3. 	The Clerk of Court shall mark the case as CLOSED.
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Date: February 5, 2026 	________________________
Adam B. Abelson
United States District Judge
/s/
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