A federal lawsuit filed by Brahim Boumakh against Sandra Jaldin and her daughter, stemming from a chaotic apartment leasing experience that allegedly involved contract breaches and physical assault, has been thrown out by a U.S. District Court judge. The dismissal wasn’t based on the merits of the claims—whether the lease was broken or if an assault occurred—but rather on a fundamental issue: the court determined it lacked the authority, or “subject-matter jurisdiction,” to hear the case in the first place.
Judge Trevor N. McFadden ruled that Boumakh failed to adequately establish either “diversity jurisdiction” or “federal question jurisdiction,” the two primary paths for bringing a case in federal court when state law claims are involved.
The Messy Lease Signing
Boumakh, who represented himself (proceeding *pro se*), detailed a troubling encounter in April 2025. He alleged that after negotiating the terms of a lease for an apartment owned by Jaldin in Washington, D.C., the situation rapidly deteriorated. According to his complaint, after signing the lease documents, Jaldin allegedly “forcibly seized the lease agreement from his hand by twisting his arm” and fled. Compounding the matter, Boumakh claimed Jaldin’s daughter then physically assaulted him, seizing him by the neck and throwing him to the ground.
Based on these allegations, Boumakh sued for breach of contract, tortious interference, and assault and battery. He sought substantial damages, including $100,000 for emotional distress, $250,000 in punitive damages, and tens of thousands more for consequential and special damages, plus legal fees. He also requested an emergency injunction to force Jaldin to honor the lease.
The defendants, Jaldin and her daughter, immediately moved to dismiss the case under Federal Rule of Civil Procedure 12(b)(1), arguing the court lacked jurisdiction.
The Jurisdiction Hurdle: Complete Diversity
Federal courts operate with limited jurisdiction. To hear a case like this one—which involves state-law claims like contract disputes and assault—the court typically relies on diversity jurisdiction. This requires two strict conditions: first, the amount in controversy must exceed $75,000 (which Boumakh easily cleared with his claims); and second, there must be “complete diversity.” Complete diversity means that *no* plaintiff can share the same state citizenship as *any* defendant.
Boumakh asserted in his complaint that the matter “involves citizens of different states,” but the court noted that it does not accept such bald legal conclusions without supporting facts.
The court must look at where each party is “domiciled”—their physical presence combined with the intent to remain indefinitely.
Boumakh’s Citizenship Established
The judge found that Boumakh’s own filings pointed clearly to one location. Boumakh identified himself as a “resident of the United States” and provided an address in Arlington, Virginia. Furthermore, his reason for seeking the lease—to find housing within a specific school district for his children—suggested a settled intent to remain in that area. The court concluded Boumakh was a citizen of Virginia.
The Defendants’ Murky Status
The path became complicated when assessing the citizenship of Sandra Jaldin and her daughter. Boumakh suggested Jaldin had ties to both Washington, D.C. (where the meeting took place) and Bolivia (alleging she planned to abscond there).
However, Jaldin countered this by submitting a sworn declaration to establish her domicile. She asserted she has owned a home in Alexandria, Virginia, since 1996, holds a Virginia driver’s license, and has filed Virginia tax returns for two decades. Crucially, she stated that no matter where she travels internationally, she always returns to her Virginia home. The court noted that Boumakh offered no factual rebuttal to these specific claims.
The judge ruled that while Jaldin may travel or even spend significant time abroad (like in Bolivia, as Boumakh alleged), “mere absence from a fixed home, however long continued, cannot work the change” in domicile. Based on the evidence provided, Jaldin was also deemed a citizen of Virginia.
Fatal Flaw: The Missing Daughter
Even if Jaldin’s citizenship had been clearly different from Boumakh’s, the case would still fail due to the second defendant: Jaldin’s daughter.
The opinion states plainly that Boumakh provided “no allegations about the citizenship of Jaldin’s daughter.” Because the plaintiff bears the entire burden of pleading the citizenship of *every* party to establish complete diversity, this omission was “alone fatal to Boumakh’s Complaint.”
No Backup Plan: Federal Question Jurisdiction
Boumakh had briefly mentioned federal question jurisdiction in a reply brief, but the court found this insufficient. Federal question jurisdiction applies when a federal law forms an essential part of the plaintiff’s case as presented on the face of the complaint. Boumakh’s claims—breach of contract, assault, and interference—are all matters of state law, raising no federal issues.
Conclusion and Next Steps
Because the plaintiff failed to prove that complete diversity existed between him (a likely Virginia citizen) and the defendants (at least one of whom, Jaldin, appeared to be a Virginia citizen, and the other whose citizenship was unstated), the court concluded it had no subject-matter jurisdiction.
The Complaint was dismissed “without prejudice.” This means Boumakh is free to refile his case, but he must do so in a court that *does* have jurisdiction—most likely a state court in Virginia or D.C., where the events occurred, or potentially refile in federal court if he can properly establish complete diversity among all parties. All other pending motions, including his request for an emergency injunction, were denied as moot.