Williams v. Dallas Area Rapid Transit

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
VINCENT TYRONE WILLIAMS, §
PLAINTIFF, §
§
V. § CIVIL CASE NO. 3:26-CV-177-E-BK
§
DALLAS AREA RAPID TRANSIT TRAIN §
OPERATOR, §
DEFENDANT. §
FINDINGS, CONCLUSIONS AND RECOMMENDATION
OF THE UNITED STATES MAGISTRATE JUDGE
Pursuant to 28 U.S.C. § 636(b) and Special Order 3, this pro se civil action was referred
to the United States magistrate judge for case management, including the entry of findings and a
recommended disposition. The Court granted Plaintiff’s motion for leave to proceed in forma
pauperis but did not issue service of process pending judicial screening. Doc. 5. Upon review of
the relevant pleadings and applicable law, this action should be DISMISSED WITHOUT
PREJUDICE for lack of subject matter jurisdiction.
I. BACKGROUND
On January 21, 2026, Plaintiff Vincent Tyrone Williams, a Texas state inmate, filed a
complaint against an unidentified train operator at Dallas Area Rapid Transit (DART) in Dallas,
Texas. Doc. 3 at 1. Although he filed the complaint on the prisoner-civil-rights-complaint form,
Williams raises only negligence claims against the train operator. Doc. 3 at 6-7. Specifically,
Williams asserts that on October 5, 2024, while trying to board a DART train, the train operator
twice closed the train doors on Williams injuring him. Doc. 3 at 4, 6. Also, the train operator
allegedly (1) failed to open the train doors later on, preventing Williams from exiting the train to
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seek medical attention, and (2) subsequently left him on the platform, after Williams had exited
the train to use the restroom. Doc. 3 at 6. Williams asserts that he went to Methodist Hospital
for x-rays the next day and was prescribed medications. Doc. 3 at 7. He seeks compensatory
and punitive damages for physical injuries and mental anguish. Doc. 3 at 4.
II. ANALYSIS
The Court should always examine, sua sponte, if necessary, the threshold question of
whether it has subject matter jurisdiction. The Lamar Co., L.L.C. v. Mississippi Transp.
Comm'n, 976 F.3d 524, 528 (5th Cir. 2020); FED. R. CIV. P. 12(h)(3) (“If the court determines at
any time that it lacks subject-matter jurisdiction, the court must dismiss the action.”). Unless
otherwise provided by statute, a federal district court has subject-matter jurisdiction over (1) a
federal question arising under the Constitution, a federal law, or a treaty, see 28 U.S.C. § 1331,
or (2) a case in which there is complete diversity of citizenship between parties and the matter in
controversy exceeds $75,000, see 28 U.S.C. § 1332. “Under the well-pleaded complaint rule, ‘a
federal court has original or removal jurisdiction only if a federal question appears on the face of
the plaintiff’s well-pleaded complaint; generally, there is no federal jurisdiction if the plaintiff
properly pleads only a state law cause of action.’” Gutierrez v. Flores, 543 F.3d 248, 251-52
(5th Cir. 2008). Further, the plaintiff, as the party asserting subject-matter jurisdiction, bears the
burden of establishing that subject matter jurisdiction exists. See Willoughby v. U.S. ex rel. U.S.
Dep’t of the Army, 730 F.3d 476, 479 (5th Cir. 2013).
The Court must also liberally construe pleadings filed by pro se litigants. See Erickson v.
Pardus, 551 U.S. 89, 94 (2007) (noting pro se pleadings are “to be liberally construed” and “held
to less stringent standards than formal pleadings drafted by lawyers”); Cf. FED. R. CIV. P. 8(e)
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(“Pleadings must be construed so as to do justice.”). Even under the most liberal construction,
however, Williams has not alleged facts that establish federal question or diversity jurisdiction.
“A federal question exists only [in] those cases in which a well-pleaded complaint
establishes either that federal law creates the cause of action or that the plaintiff’s right to relief
necessarily depends on resolution of a substantial question of federal law.” Singh v. Duane
Morris LLP, 538 F.3d 334, 337-38 (5th Cir. 2008) (citation and internal quotation marks
omitted). Williams’ complaint, however, contains no factual allegations that support federal
question jurisdiction. At best, Williams alleges only state-law negligence claims against the
DART train operator. See Spencer v. DART, No. 3:05-CV-2041-N (N.D. Tex. May 12, 2006)
(dismissing negligence action against DART for lack of subject matter jurisdiction). And the
mere fact that Williams filed his complaint on the prisoner-civil-rights-complaint form does not
change the fact that he asserts no factual allegations that would support a plausible federal civil
rights claim.
“[F]ederal courts are without power to entertain claims otherwise within their jurisdiction
if they are so attenuated and unsubstantial as to be absolutely devoid of merit . . . .” Hagans v.
Levine, 415 U.S. 528, 536-37 (1974) (internal citation and quotation marks omitted); see Murphy
v. Inexco Oil Co., 611 F.2d 570, 573 (5th Cir. 1980) (“[T]he assertion that the claim involves [a
federal] question must be more than incantation.”). Therefore, Williams allegations are
insufficient to invoke the Court’s federal question jurisdiction. See Girard v. CitiMortgage, Inc.,
No. 12-CV-4264-N, 2013 WL 5873297, at *2 (N.D. Tex. Nov. 1, 2013) (Godbey, J.) (adopting
magistrate judge’s dismissal recommendation because plaintiff’s “single passing reference” to a
federal statute did not constitute a cause of action, and was not “sufficient to support the exercise
of federal question jurisdiction”).
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Further, Williams’ assertions that he and the DART train operator are both in Texas,
defeats subject-matter jurisdiction based on diversity over his negligence claims. Doc. 3 at 3.
See Corfield v. Dallas Glen Hills LP, 355 F.3d 853, 857 (5th Cir. 2003) (finding district court
cannot exercise diversity jurisdiction if the plaintiff shares the same state of citizenship as any
one of the defendants) (citation omitted); Preston v. Tenet Healthsystem Mem’l Med. Ctr., Inc.,
485 F.3d 793, 799 (5th Cir. 2007) (“For diversity purposes, citizenship means domicile; mere
residence in [a] [s]tate is not sufficient.”) (citation and quotation marks omitted).
Finally, because the complaint does not present an adequate basis for federal question
jurisdiction, and Williams cannot rely on diversity jurisdiction, the Court cannot exercise
supplemental jurisdiction over any possible state-law claims that he may be attempting to assert.
28 U.S.C. § 1367(a).
Accordingly, the complaint should be dismissed sua sponte and without prejudice for
lack of subject matter jurisdiction.
III. LEAVE TO AMEND
Ordinarily, a pro se plaintiff should be granted leave to amend his complaint before
dismissal, but leave is not required when he has already pleaded his “best case.” Brewster v.
Dretke, 587 F.3d 764, 767-68 (5th Cir. 2009). As demonstrated above, the facts as alleged in
Williams’ complaint demonstrate a lack of subject matter jurisdiction in this Court that is not
curable by amendment. Thus, the Court concludes that Williams has already pleaded his best
case and granting leave to amend would be futile and cause needless delay.
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IV. CONCLUSION
For all these reasons, Williams’ action should be DISMISSED WITHOUT
PREJUDICE for lack of subject matter jurisdiction. See FED. R. CIV. P. 12(h)(3).
SO RECOMMENDED on January 27, 2026.
INSTRUCTIONS FOR SERVICE AND
NOTICE OF RIGHT TO APPEAL/OBJECT
A copy of this report and recommendation will be served on all parties in the manner provided by
law. Any party who objects to any part of this report and recommendation must file specific
written objections within 14 days after being served with a copy. See 28 U.S.C. § 636(b)(1); FED.
R. CIV. P. 72(b). An objection must identify the finding or recommendation to which objection is
made, the basis for the objection, and the place in the magistrate judge’s report and
recommendation the disputed determination is found. An objection that merely incorporates by
reference or refers to the briefing before the magistrate judge is not specific. Failure to file specific
written objections will bar the aggrieved party from appealing the factual findings and legal
conclusions of the magistrate judge that are accepted or adopted by the district court, except upon
grounds of plain error. See Douglass v. United Servs. Auto. Ass’n, 79 F.3d 1415, 1417 (5th Cir.
1996), modified by statute on other grounds, 28 U.S.C. § 636(b)(1) (extending the time to object
to 14 days).
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