Eleventh Circuit Decision Highlights Difficulty of Invoking Federal-Question Jurisdiction Over Claim for Declaratory Relief

The United States Constitution created federal courts of limited subject-matter jurisdiction. Thus, a party filing suit in federal court must assert a claim arising under federal law or demonstrate that the litigants are citizens of different states. Generally, a claim brought pursuant to the federal Declaratory Judgment Act is alone insufficient to invoke federal-question jurisdiction. In Patel v. Hamilton Medical Center, Inc., the Eleventh Circuit reaffirmed this principle, holding “a plaintiff cannot create federal-question jurisdiction by seeking a declaration that a federal defense does not protect the defendant.” 2020 WL 4355263 (11th Cir. July 30, 2020).

In Patel, a gastroenterologist filed suit in federal court against a medical center for temporarily suspending his admitting privileges. The physician sought damages under state law but also requested a declaration that the medical center was not entitled to immunity under the federal Health Care Quality Improvement Act (“HCQIA”). The parties were not diverse, but the physician alleged that the district court had federal-question jurisdiction over his request for declaratory relief and supplemental jurisdiction over his state law claims. The district court agreed but held on summary judgment that the medical center was, in fact, immune from liability pursuant to the HCQIA.

On appeal, the Eleventh Circuit sua sponte raised the issue of subject-matter jurisdiction, observing that a claim seeking declaratory relief does not give rise to federal-question jurisdiction unless “a plaintiff’s well-pleaded complaint alleges facts demonstrating the defendant could file a coercive action arising under federal law.” And, because the HCQIA creates an affirmative defense, not a private right of action, the court concluded that the medical center could not file a coercive action against the physician. In other words, the physician’s request for declaratory relief was insufficient to establish federal-question jurisdiction. Accordingly, the Eleventh Circuit vacated the judgment and remanded the case with instructions to dismiss the complaint for lack of subject-matter jurisdiction. The case is a cautionary tale for any plaintiff intending to invoke the jurisdiction of a federal court based solely on a request for declaratory relief.

Posted by John Sharpe.

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