Federal Judge Dismisses Church Dispute Case, Finding No Basis for Federal Jurisdiction

Lisbeth Russo, a Mississippi resident proceeding pro se, sued her church pastor Courtney Stamey in federal court, alleging state law claims for malicious prosecution, intentional infliction of emotional distress, libel, and slander stemming from activities at their church, including Russo's apparent arrest on church property. Russo sought lost wages, court costs, towing costs, and punitive damages, while also attempting to assert federal civil rights violations under 18 U.S.C. sections 241 and 242.

Judge Reeves dismissed the case sua sponte after finding no basis for federal subject matter jurisdiction. "Federal courts are courts of limited jurisdiction. They possess only that power authorized by Constitution and statute," Reeves wrote, emphasizing that "subject matter jurisdiction cannot be waived, nor may the parties confer jurisdiction upon the court either by their conduct or consent."

The court delivered its sharpest criticism of Russo's attempt to invoke federal criminal statutes as the basis for civil claims. "Nothing in sections 241 or 242 indicates that they are more than 'bare criminal statutes,'" Judge Reeves wrote, adding that "the fact that a federal statute has been violated and some person harmed does not automatically give rise to a private cause of action in favor of that person."

The case reached federal court on April 2, 2026, when Russo filed her complaint without establishing any basis for federal jurisdiction. Since both parties are Mississippi residents and the complaint did not demonstrate that the amount in controversy exceeds $75,000, the court found it lacked diversity jurisdiction under 28 U.S.C. section 1332, which requires "complete diversity" of citizenship between the parties.

Judge Reeves systematically rejected Russo's attempts to establish federal question jurisdiction. Beyond finding that the criminal statutes cited provide no private right of action, the court noted that any potential First Amendment claim would fail because "the defendant is a private citizen" and "the First Amendment constrains governmental actors," not private parties like a church pastor.

The dismissal was without prejudice, meaning Russo could potentially refile her state law claims in Mississippi state court, where they would be properly adjudicated. The ruling underscores the fundamental principle that federal courts cannot hear cases simply because a plaintiff prefers federal forum over state court.

The decision reflects routine enforcement of jurisdictional limits that prevent federal courts from becoming general tribunals for state law disputes. For practitioners, the case serves as a reminder that invoking federal criminal statutes in civil complaints requires careful analysis of whether Congress intended to create a private cause of action.