E) General, Permanent Injunctive Relief. The Plaintiff requests permanent injunctive relief (under 28 U.S.C. §1343) prohibiting all Defendants, their agents, successors, assigns, or anyone acting in concert with them, from engaging in any actions intended for the purpose, or likely to cause, interference with the Plaintiff’s constitutionally protected liberty interests under the Fourteenth Amendment, unless and until Plaintiff is first provided the procedural safeguards articulated in Coleman v. Dretke, 395 F.3d 216 (5th Cir. 2004) and Meza v. Livingston, 607 F.3d 392 (5th Cir. 2010).64 The Plaintiff would respectfully submit again that in view of the official, persistent and enduring policy of the Department Defendants to enforce Article 62.001(5)(E) of the Texas Code of Criminal Procedure in a manner that requires Plaintiff (and others similarly situated) to register as a “sex offender” (notwithstanding settled law as stated in Coleman v. Dretke and Meza v. Livingston, supra), there is no fair assurance that the Department Defendants will yield to a mere

See, e.g., Daniel v. Ferguson, 839 F.2d 1124, 1127 (5th Cir. 1988) (a distinction must be drawn between a court’s jurisdiction under § 1343 to hear a § 1983 claim and the adequacy of that claim); York v. Story, 324 F.2d 450, 453 (9th Cir. 1963), cert. denied, 376 U.S. 939 (1964) (28 U.S.C. § 1943 "was enough to establish district court jurisdiction [over a § 1983 claim], whether or not appellant succeeded in stating such a claim"). Even if the Court were to find that a different subject- matter-jurisdiction defense, such as the Rooker-Feldman doctrine, applied here, that still would not be grounds for the Court to hold that it lacks jurisdiction under 28 U.S.C. §§ 1331 and 1343, as this case unquestionably satisfies the requirements of both of those sections. Defendant’s hyper-technical jurisdiction argument is, in any event, entirely hypothetical and beside the point.

See Lynch v. Household Finance Corp., 405 U.S. 538, 540 (1972). Plaintiff’s suit, however, is against federal officials, who do not act “under color of any State law,” which is the prerequisite to jurisdiction under 28 U.S.C. § 1343. That statute has no bearing here.

¶ 13. Section 1343 grants district courts original jurisdiction over civil rights and voting rights suits falling into four categories, enumerated at 28 U.S.C. §§ 1343(a)(1) – (4). Because Jordan does not assert a claim included within § 1343’s enumerated list of relevant civil actions, she cannot rely on § 1343 as a basis for federal jurisdiction.

Civil rights and elective franchise states in pertinent part: (a) The district courts shall have original jurisdiction of any civil action authorized by law to be commenced by any person: .... (3) To redress the deprivation, under color of any State law, statute, ordinance, regulation, custom or usage, of any right, privilege or immunity secured by the Constitution of the United States or by any Act of Congress providing for equal rights of citizens or of all persons within the jurisdiction of the United States; (4) To recover damages or to secure equitable or other relief under any Act of Congress providing for the protection of civil rights, including the right to vote. Plaintiff has the right to secure equitable relief under 28 U.S.C. 1343(a)(3) and (4). In Baker v. Carr, 369 U.S. 186 (1962), federal jurisdiction arose under this section and Plaintiff had standing because his individual right to vote was affected.

The Levee District is not a citizen for purposes of diversity jurisdiction and even if the Levee District were considered a citizen, the Levee District and the Plaintiff would both be citizens of Louisiana, such that there can be no argument that complete diversity exists in this case. B. Subject Matter Jurisdiction- Ripeness This Court may not exercise Federal Question jurisdiction pursuant to 28 U.S.C. § 1331 or Civil Rights jurisdiction under 28 U.S.C. § 1343(a)(3), because the Plaintiff’s takings claim is not yet ripe for adjudication. Ripeness is a question of law regarding the Court’s subject matter jurisdiction.

. Plaintiff’s allegations are too conclusory to state a claim against Dr. Barnes and must be dismissed. Bell v. Twombly, supra, and Ashcroft v. Iqbal, supra; Fed.R.Civ.P. 12(b)(6). Plaintiff invokes the jurisdiction of this Court under 28 U.S. §§1331, 1343 & 1367. No diversity exists between Plaintiffs and Defendants; jurisdiction cannot be supported under 28 U.S.C. §1332.

The Complaint states no cognizable federal cause of action under 28 U.S.C. §1331. The Complaint describes no violation of civil rights that could support jurisdiction under 28 U.S.C. §1343. The Complaint describes no threatened deprivation of anyone’s life, liberty, or property without due process of law.

This Court Has Independent Grounds for Jurisdiction Fairbank’s claims arise under the Eighth and Fourteenth Amendments to the United States Constitution and 42 U.S.C. § 1983. This Court has independent grounds for jurisdiction pursuant to 28 U.S.C. § 1331 (federal question) and 28 U.S.C. § 1343 (civil rights). 2.

This Court Has Independent Grounds for Jurisdiction Pinholster’s claims arise under the Eighth and Fourteenth Amendments to the United States Constitution and 42 U.S.C. § 1983. This Court has independent grounds for jurisdiction pursuant to 28 U.S.C. § 1331 (federal question) and 28 U.S.C. § 1343 (civil rights). 2.