Personal-jurisdiction-versus-forum-non-conveniens

question presented is whether the district court made clear error in dismissing the complaint for want or lack of personal jurisdic: . tion rather than because of forum non conveniens or venue for this matter, because, in the case at bar, the Western District Court of Michigan does have both personal and subject matter jurisdictions. Fed. R. Civ. P. §§ 1331, 1332 (a)(1) It is a settle rule of this Court that when an American party sues another American party in federal court, at least one thing is certain, so long as some court in the United States has jurisdiction (personal and subject matter) over the case, the case will be heard. Here, the federal question element is met. The | | | | ii matter in controversy exceeds the sum or value of the jurisdictional amount and the petitioner and respondents are citizens of different states. Hence, the federal court has jurisdiction (personal and subject matter). Therefore, it is clear error that the district courts dismissed the complaint for personal jurisdiction rather than because of forum non conveniens or ; improper venue. It is thus fair to say that if federal : court 1 has jurisdiction, (personal and subject matter), it would be improper for federal court 2 to dismiss the case for personal jurisdiction when federal court 1 has personal jurisdiction. This is where the forum non-conveniens doctrine, improper venue and transfer provisions come into play. Hence the dismissal for lack of personal jurisdiction was improper because the Michigan Western District Court as the actus forum does have jurisdiction (personal and subject matter). 2. The second question presented is whether on principles governing federal courts, the Supreme Court should exercise its jurisdiction on certiorari where, as here, the judgment in the Western Michigan ; Ingham County Circuit Court obtained through proven fraudulent and unethical means by the respondent law school caused direct, specific, and concrete injury to the student petitioning for review, (App. 1f Bill of Complaint), as well as to the . federal agency, here, the Department of Education and requisites of controversy were met. ; 3. The third question presented is whether on principles governing federal courts there exists an available alternative forum for the action as adequate relief cannot be obtained in any other form | | | iii or from any other state or federal court because of the initial unethically hence fraudulently obtained judgment in the Ingham County Circuit Court, ; App 1f, which lead to all the following corrupted federal courts judgments, which on principles of federal laws, the Supreme .Court should declare void ab-initio, because it was obtained in violation ; of petitioner’s Fundamental Constitutional Rights to Freedom of Speech, 1st Amendment , 4th . 5th and 14th Amendments, to Equal Protection, Due Process (procedural and substantive), the Code for ‘Judicial Conduct, as well as Rule 60 of the Federal Rules of Civil Procedures. 4. The fourth question presented is whether respondent law school, as a private entity, performs a traditional, exclusive public function, i.e. educating or training lawyers and future judges for both federal, state, and local courts, qualifies as a state actor in this limited circumstance and hence is subject to . constitutional liability.