The following excerpt is from Hall v. Mooretown Rancheria/Feather Falls Casino, No. 2:12-cv-1856 LKK GGH PS (E.D. Cal. 2013):
A less stringent examination is afforded pro se pleadings, see Haines v. Kerner, 404 U.S. 519, 520 (1972), but simple reference to federal law does not create subject matter jurisdiction. Avitts v. Amoco Prod. Co., 53 F.3d 690, 694 (5th Cir. 1995). Subject matter jurisdiction is created only by pleading a cause of action that is within the court's original jurisdiction. Id.
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