Knox County, Tennessee v. United States of America, et. al.
MEMORANDUM OPINION. Signed by District Judge R Leon Jordan on 11/27/17. (JBR)
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TENNESSEE
KNOX COUNTY, TENNESSEE,
UNITED STATES OF AMERICA, and
This matter is before the Court on the United States’ Motion to Dismiss [doc. 12],
the United States’ Brief in Support of the Motion [doc. 13], Plaintiff’s Response in
Opposition [doc. 18], and the United States’ Reply [doc. 19.]. For the reasons herein, the
Court will grant the United States’ motion.
Plaintiff Knox County, Tennessee, (“Knox County”) brings this action under the
Federal Declaratory Judgment Act, 28 U.S.C. § 2201, mounting its most recent challenge
to the Court’s final order of forfeiture in a long defunct civil forfeiture case. [See Consent
Order of Forfeiture, doc. 19, United States v. Real Prop. Located at 1308 Selby Lane,
Knoxville, Tenn. 37922, No. 3:10-CV-423 (E.D. Tenn. Sept. 27, 2012)]. Specifically, Knox
County moves the Court to declare, among other things, that it “has a valid perfected lien
securing taxes assessed against” the forfeited property and that the Court’s final order of
forfeiture is “void as to Knox County’s liens.” [Compl., doc. 1, ¶¶ 46, 47]. The United
States moves to dismiss Knox County’s Complaint, arguing that the Court lacks subject
matter jurisdiction. [United States’ Br. at 5–10].
The Declaratory Judgment Act states that “[i]n a case of actual controversy within
its jurisdiction . . . any court of the United States, upon the filing of an appropriate pleading,
may declare the rights and other legal relations of any interested party seeking such
declaration.” 22 U.S.C. § 2201(a) (emphasis added)). “In recognition of the Constitution’s
limit on judicial authority,” the statute’s plain language allows for “declaratory relief only
‘[i]n a case of actual controversy.’” Fieger v. Mich. Supreme Court, 553 F.3d 955, 961 (6th
Cir. 2009) (emphasis added) (quoting 28 U.S.C. § 2201(a)); see U.S. Const. art. III, § 2
(empowering the federal judiciary to hear only “Cases” and “Controversies”); see also
Simon v. E. Ky. Welfare Rights Org., 426 U.S. 26, 37 (1976) (“No principle is more
fundamental to the judiciary’s proper role in our system of government than the
constitutional limitation of federal-court jurisdiction to actual cases or controversies.”
The Court has already ruled that Knox County is without standing in the civil
forfeiture case—the very case in which it wants the declaratory judgment to apply. [See
Mem. Op., doc. 43, United States v. Real Prop. Located at 1308 Selby Lane, Knoxville,
Tenn. 37922, No. 3:10-CV-423 (E.D. Tenn. Sept. 19, 2017)]. Since the Court’s ruling,
Knox County has made no effort to attain standing. The case has remained closed and
inactive. Because Knox County lacks standing in the forfeiture case, there exists no actual
case or controversy over which the Court can enter a declaratory judgment, and it therefore
lacks jurisdiction. See Fieger, 553 F.3d at 961 (“Article III’s ‘case and controversy’
requirement is not satisfied, and a court therefore has no jurisdiction, when the claimant
lacks standing, that is, ‘a sufficiently concrete and redressable interest in the dispute.’”
(quotation omitted)); see also Blakely v. United States, 276 F.3d 853, 872 (6th Cir. 2002)
(recognizing that a declaratory judgment is improper unless “there is a substantial
controversy, between parties having adverse legal interests, of sufficient immediacy [and]
reality to warrant the issuance of a declaratory judgment” (citing Golden v. Zwickler, 394
U.S. 103, 108 (1969))); cf. Cooper v. Rapp, No. 17-3068, 2017 WL 3142321, at *4–5
(determining that the plaintiffs’ “request for a declaratory judgment is barred by Article
III’s case-or-controversy requirement” because the defendant was not a party in the
underlying state-court proceedings).
The Court lacks subject matter jurisdiction over this action. The United States’
Motion to Dismiss [doc. 12] is therefore GRANTED. The Clerk of Court is DIRECTED
to close this case.
IT IS SO ORDERED.
s/ Leon Jordan
United States District Judge
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