Court Finds that it Lacks Jurisdiction to Issue Declaratory Judgment in Copyright Case Involving Mental Health Survey
On August 26 of 2024, we published a post discussing a lawsuit filed by Miranda Stovall (“Stovall” or “Plaintiff”), a student’s mother, against Jefferson County Public Schools ("JCPS" or "Defendants"). The complaint arose after JCPS denied her request for copies of a mental health survey administered to students in the district where her child was enrolled. Stovall asked a federal district court in Kentucky to issue a declaratory judgment on whether the release of copyrighted material by a state agency for non-commercial purposes constitutes copyright infringement.
The Defendants challenged Stovall's suit by arguing that the federal court lacked jurisdiction to address the issue, asserting that it was a matter of state law and should therefore be litigated in state court.
On March 18, Judge Jennings issued a Memorandum Opinion and Order siding with the Defendants. In denying Stovall’s request, the court emphasized that a declaratory judgment is not meant to serve as a tool for parties to change “tribunal from a state to a federal court,” nor should it be used “[to anticipate] a defense that otherwise could be presented in a state action” (5). According to Judge Jennings, Stovall’s action sought to preemptively obtain a federal ruling on a potential defense that might arise in future state court proceedings.
The court ultimately found that it lacked jurisdiction to adjudicate the case. As a result, it granted the Defendants’ motion to dismiss, terminating the case. Stovall has filed a Notice of Appeal, however, so we may see this case resurface in the future.