United States District Court, D. Minnesota
MEMORANDUM AND ORDER
A. Magnuson United States District Court Judge
matter is before the Court on Defendants' Motions to
Dismiss. For the following reasons, the Motions are granted.
Amy Hamilton-Warwick brought this lawsuit complaining about
the alleged mistreatment of monkeys in an alleged experiment
conducted to analyze the effects of diesel exhaust on human
health, which she learned about in a Netflix documentary
called Dirty Money. She claims that Defendants “acted
immorally and illegally under the laws of the United States
by abusing and cruely [sic] murdering individuals and animals
to demonstrate previously researched and proven circumstances
to defraud and further harm U.S. Citizens.” (Compl.
(Docket No. 1) at 8.) She admits, however, that no monkeys
were killed in these alleged experiments. (Id. at
are Volkswagen Group of America, Daimler Trucks, BMW of North
America, the Lovelace Respiratory Research Institute, the
Environmental Protection Agency, and Netflix. Although the
Complaint contains no causes of action, Plaintiff quotes from
several statutes: 18 U.S.C. §§ 1801, 3283; 42
U.S.C. §§ 1981, 1986; N.M. Stat. Ann. §§
30-6-1, 30-18-1; and Ohio Rev. Code § 959.13. She also
cites one federal regulation, 49 C.F.R. § 801.56.
Plaintiff asks that the Court find Defendants “guilty
of the charges laid out in the attached documents” and
order that Defendants “contribute money to fund the
recovery of animals to a group much like the World Wildlife
Fund.” (Compl. at 4.)
Defendants raise several different arguments in support of
their Motions, their common arguments are that Plaintiff
lacks standing and that her Complaint fails to state any
claims on which relief can be granted. They are correct on
Plaintiff recognizes, federal courts are courts of limited
jurisdiction. And while Plaintiff invokes this Court's
diversity jurisdiction under § 1332, another component
of federal jurisdiction is the requirement that the plaintiff
has standing to bring her claims. Standing “is an
essential and unchanging part of the case-or-controversy
requirement of Article III.” Lujan v. Defs. of
Wildlife, 504 U.S. 555, 560 (1992). It “is founded
in concern about the proper-and properly limited-role of the
courts in a democratic society.” Warth v.
Seldin, 422 U.S. 490, 498 (1975). This Court has no
jurisdiction over Plaintiff's claims unless she has
establish standing to bring a case in federal court,
Plaintiff must demonstrate that she has personally suffered a
concrete and actual injury that is traceable to
Defendants' conduct and likely to be redressed by a
favorable federal court decision. Lujan, 504 U.S. at
560; see also Allen v. Wright, 468 U.S. 737, 751
(1984). Plaintiff fails at each step of the standing inquiry.
the only personal injury Plaintiff alleges is that she is
upset and “disappointed” by Defendants'
alleged conduct. (Compl. at 15.) But her disappointment is
not a concrete injury cognizable in federal court.
Spokeo, Inc. v. Robbins, 136 S.Ct. 1540, 1548 (2016)
(“A ‘concrete' injury must be ‘de
facto'; that is, it must actually exist”).
Plaintiff alleges that animals were injured in the testing
about which she complains, the Article III “judicial
power exists only to redress or otherwise to protect against
injury to the complaining party.” Warth, 422
U.S. at 499. In other words, “[t]o meet the
injury-in-fact requirement, the party seeking relief must be
[herself] among the injured.” Cmty. Stablilization
Project v. Cuomo, 199 F.R.D. 327, 331 (D. Minn. 2001)
(Montgomery, J.) Because Plaintiff suffered no concrete and
particularized injury, she does not have standing to pursue
had Plaintiff sufficiently demonstrated an injury, she has
not established that such injury is traceable to
Defendants' conduct. She complains about animal testing
at Lovelace's New Mexico facility, ostensibly at the
behest of Defendant automobile manufacturers. How Netflix or
the EPA are responsible for this conduct is unexplained.
Plaintiff's alleged injury simply cannot be redressed by
the relief she seeks. She asks that Defendants be held
accountable for their behavior and ordered to pay money to a
wildlife-protection organization. Such relief will not
redress any injury Plaintiff could possibly ...