Seaton v. Seaton

Decision Date01 July 1997
Docket NumberNo. 3:96-cv-741.,3:96-cv-741.
PartiesLaurel Knuckles SEATON, Plaintiff, v. Kenneth Marshall SEATON, Defendant.
CourtU.S. District Court — Eastern District of Tennessee

Melvin J. Werner, Werner and Associates, Kingsport, TN, for plaintiff.

Perry P. Paine, Jr., Paine, Garrett & Bray, Maryville, TN, for defendant.

MEMORANDUM OPINION

JARVIS, Chief Judge.

This is an action for damages brought pursuant to the Violence Against Women Act (VAWA), 42 U.S.C. § 13981. Included in plaintiff's complaint are various pendent state law claims brought pursuant to this court's supplemental jurisdiction. See 28 U.S.C. § 1367. Currently pending is defendant's motion to dismiss or, in the alternative, for summary judgment, [Doc. No. 3] on the ground that VAWA is an unconstitutional extension of Congress' powers under both the Commerce Cause of Art. I, Sec. 8, Cl. 3 of the United States Constitution and the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution. Defendant further moves to dismiss the pendent state law claims on the grounds that they are barred by the one-year Tennessee statute of limitations, Tenn.Code Ann. § 28-3-104; that they raise novel or complex issues of law and should be dismissed pursuant to 28 U.S.C. § 1367(c)(1); and that there are other compelling reasons for denying, supplemental jurisdiction, 28 U.S.C. § 1367(c)(4). For the reasons that follow, the motion will be denied as to the federal claim and granted as to the supplemental state law claims.

I. Factual Background

Plaintiff Laurel Knuckles Seaton and defendant Kenneth Marshall Seaton were married on February 14, 1992. Plaintiff alleges that, during the courtship prior to the marriage and throughout the marriage, defendant engaged in controlling, deceitful and abusive behavior, of which plaintiff was the victim. Plaintiff alleges that she was the victim of conspiracy, fraud, physical and sexual abuse, and emotional suffering.

On August 23, 1995, plaintiff filed for divorce from defendant after an alleged final altercation occurring on August 22, 1995. Plaintiff alleges that during the altercation, defendant severely threatened and assaulted her. Plaintiff's divorce complaint was filed in the Fourth Circuit Court for Knox County, Tennessee. In her divorce complaint, plaintiff asked for a divorce as well as civil damages resulting from defendant's alleged tortious conduct toward plaintiff. The charges in the state complaint include assault and battery, outrageous conduct, fraud, civil conspiracy, and defamation.

On August 22, 1996, plaintiff filed the instant action, in which she sets forth a primary federal claim that defendant, by his aforementioned actions, violated VAWA (Count I). The complaint also alleges related state law claims, including assault and battery (Count II), intentional infliction of emotional distress (Count III), false imprisonment (Count IV), breach of fiduciary duty (Count V), fraud and conversion (Count VI), and misrepresentation (Count VII). The complaint seeks injunctive relief, incidental and compensatory damages, exemplary and punitive damages, attorney fees and costs, and other equitable relief, including rescission.

Defendant, through his answer, denies all allegations of abuse, fraud, conspiracy, or otherwise. Additionally, defendant asserts in his dispositive motion that VAWA is unconstitutional as Congress exceeded its authority under either the Commerce Clause or the Equal Protection Clause. As such, defendant contends that, as to Count I of plaintiff's complaint seeking relief under VAWA, plaintiff has failed to state a claim upon which relief can be granted and that there is no federal jurisdiction over defendant or the subject matter of plaintiff's federal claim.

As to the state claims, defendant asserts that they should be dismissed under the provisions of 28 U.S.C. § 1367. Defendant argues that the state claims raise novel or complex issues of law, substantially predominate over the claim made under VAWA, and invoke circumstances providing other compelling reasons for declining jurisdiction — namely that many, if not all, of the same claims are pending in a divorce suit between the parties in state court.

Finally, defendant asserts that, with the exception of the final altercation, all of the actions alleged by plaintiff occurred over one year before the filing of the original federal complaint and are, therefore, barred by the Tennessee statute of limitations for civil actions.

II. Summary Judgment Standard

Under Fed.R.Civ.P. 56(c), summary judgment is proper if there is no genuine issue as to any material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 322-23, 106 S.Ct. 2548, 2552-53, 91 L.Ed.2d 265 (1986). The facts and all reasonable inferences to be drawn therefrom are viewed in a light most favorable to the non-moving party in determining if a genuine issue of material fact exists. See Oakland Gin Co. v. Marlow (In re The Julien Co.), 44 F.3d 426, 429 (6th Cir.1995); Kunz v. United Food & Commercial Workers, Local 876, 5 F.3d 1006, 1008-09 (6th Cir.1993). The moving party bears the burden of showing an absence of evidence to support the non-moving party's case. Celotex, 477 U.S. at 323, 106 S.Ct. at 2552-53. Lansing Dairy, Inc. v. Espy, 39 F.3d 1339, 1347 (6th Cir.1994), cert. denied, ___ U.S. ___, 116 S.Ct. 50, 133 L.Ed.2d 15 (1995).

However, once the moving party has met its initial burden, the non-moving party must present significant probative evidence in support of the complaint to defeat the summary judgment motion. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248-49, 106 S.Ct. 2505, 2510-11, 91 L.Ed.2d 202 (1986). The standard is "`whether the evidence presents a sufficient disagreement to require submission to a jury or whether it is so one-sided that one party must prevail as a matter of law.'" Street v. J.C. Bradford & Co., 886 F.2d 1472, 1479 (6th Cir.1989) (quoting Anderson, 477 U.S. at 251-52, 106 S.Ct. at 2511-12). The non-moving party is not entitled to a trial merely on the basis of allegations. Celotex, 477 U.S. at 324, 106 S.Ct. at 2553. And if the non-moving party fails to make a sufficient showing to establish any element essential to her claim on which she bears the burden of proof, the non-moving party is entitled to summary judgment. Barnhart v. Pickrel, Schaeffer & Ebeling Co., 12 F.3d 1382, 1388-89 (6th Cir.1993).

III. VAWA

Defendant contends that, by enacting VAWA, Congress exceeded its powers under the Commerce Clause, which gives Congress the power to "regulate Commerce with Foreign Nations and among the several states...."1

Before beginning an analysis of VAWA's constitutionality under the Commerce Clause, the court must note its extreme discomfort with the sweeping nature of VAWA. While there is no doubt that violence against women is a serious matter in our society, this particular remedy created by Congress, because of its extreme overbreadth, opens the doors of the federal courts to parties seeking leverage in settlements rather than true justice. The framers of the Constitution did not intend for the federal courts to play host to domestic disputes and invade the well-established authority of the sovereign states. Nevertheless, the court must heed the well-settled precedent extant in Commerce Clause jurisprudence in an effort to determine whether VAWA, even in view of its sweeping nature, passes muster under the Commerce Clause.

A. The Commerce Clause.

The power of Congress under the Commerce Clause was first defined in Gibbons v. Ogden, which established Congress' power to directly regulate interstate commerce; Gibbons allowed Congress' commerce power to spread beyond mere trafficking of goods across state lines and into the realm of "commercial intercourse." 9 Wheat. (22 U.S.) 1, 189-190, 6 L.Ed. 23 (1824). The Supreme Court in Gibbons further noted that this power "acknowledges no limitations, other than are prescribed in the Constitution." Id. at 196.

In 1937, the Supreme Court developed a standard that gave Congress the power to regulate intrastate activities which "have such a close and substantial relation to interstate commerce that their control is essential or appropriate to protect that commerce from burdens and obstructions." NLRB v. Jones & Laughlin Steel Corp., 301 U.S. 1, 37, 57 S.Ct. 615, 624, 81 L.Ed. 893 (1937) (emphasis added). Further, in determining whether Congress has acted within its limits, "the task of the court ... is relatively narrow." Hodel v. Virginia Surface Mining and Reclamation Ass'n, 452 U.S. 264, 276, 101 S.Ct. 2352, 2360, 69 L.Ed.2d 1 (1980). The court's standard of review is limited to whether a "rational basis" existed for Congress to conclude that a regulated activity sufficiently affected interstate commerce. If a rational basis is found for the statute under the Commerce Clause, the court must then consider whether the means chosen by Congress are "reasonably adapted to the end permitted by the Constitution." Id.

B. The Lopez Interpretation.

For decades following the Jones and Laughlin Steel case, Congress enjoyed the unbridled power to regulate any activity that remotely affected interstate commerce. However, in United States v. Lopez, 514 U.S. 549, 115 S.Ct. 1624, 131 L.Ed.2d 626 (1995), the Supreme Court found, for the first time in 50 years, that Congress had exceeded its power under the Commerce Clause and that a federal statute was therefore invalid. The statute in question was the Gun-Free School Zones Act, 18 U.S.C. § 922(q)(1)(A), which made it a federal offense "for any individual knowingly to possess a firearm at a place that the individual knows, or has reasonable cause to believe, is a school zone." Id.

Significantly, in affirming the Fifth Circuit Court of Appeals' finding that the Act was unconstitutional, the Supreme Court noted that it would continue to apply the rational basis test pursuant to Hodel to determine if the statute...

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