Zhengdao Zhan v. Cook County Property Tax Refund Specialists

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted October 9, 2025*
Decided October 10, 2025
Before
DAVID F. HAMILTON, Circuit Judge
DORIS L. PRYOR, Circuit Judge
JOSHUA P. KOLAR, Circuit Judge
No. 24-2039
ZHENGDAO ZHAN,
Plaintiff-Appellant,
v.
COOK COUNTY PROPERTY TAX
REFUND SPECIALISTS,
Defendant-Appellee.
Appeal from the United States District
Court for the Northern District of
Illinois, Eastern Division.
No. 24-cv-2688
Jeffrey I. Cummings,
Judge.
O R D E R
Zhengdao Zhan appeals the dismissal of his civil action seeking unpaid refunds
from a local property-tax refund specialist. Because Zhan failed to allege sufficient facts
to invoke federal jurisdiction, we affirm.
* The appellee was not served with process and is not participating in this appeal.
We have agreed to decide the case without oral argument because the briefs and record
adequately present the facts and legal arguments, and oral argument would not
significantly aid the court. F ED. R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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No. 24-2039 Page 2
Zhan sued a business named “Cook County Property Tax Refund Specialists,”
for payments that he suggests he is entitled to. He attached to his complaint an
unsolicited mail advertisement from the business suggesting that he may have overpaid
his taxes and may be entitled to a refund. Zhan’s complaint described this
advertisement as a “notification letter” that “recognized [his] record of depositing
millions” of dollars. Based on the advertisement, Zhan alleged that he was entitled to
payment of a $1 million science exhibition prize, a payment related to a case in the
Northern District of Illinois involving an “Asian Cup” football match, and a payment
related to a bet he made on the 2010 World Cup in South Africa.
After Zhan applied to proceed in forma pauperis, the district court screened his
complaint under 28 U.S.C. § 1915(e)(2)(B)(ii) and dismissed it for lack of subject matter
jurisdiction. The court determined that Zhan neither referred to any federal law under
which his action arose, see 28 U.S.C. § 1331, nor alleged sufficient facts to establish
diversity, see 28 U.S.C. § 1332(a). The court invited Zhan to seek leave to reopen the case
if he believed he could amend his complaint to assert a proper basis for subject matter
jurisdiction, but he took no such steps and instead appealed. †
On appeal, Zhan challenges the dismissal of his complaint but does not engage
with the district court’s decision that subject matter jurisdiction is lacking. He merely
elaborates about purported fraudulent transactions, gambling groups, and a conspiracy
involving domestic and foreign government officials. Although we are mindful of
Zhan’s pro se status, he still must comply with Rule 28(a) of the Federal Rules of
Appellate Procedure and include an argument explaining why the district judge’s
decision was incorrect. Cole v. Comm'r, 637 F.3d 767, 772–73 (7th Cir. 2011). Because
Zhan has not identified any federal question, see East Cent. Ill. Pipe Trades Health &
Welfare Fund v. Prather Plumbing & Heating, Inc., 3 F.4th 954, 959 (7th Cir. 2021), or facts
that would satisfy diversity jurisdiction, see Yancheng Shanda Yuanfeng Equity Inv. P'ship
v. Wan, 59 F.4th 262, 267–68 (7th Cir. 2023), we agree with the district court’s conclusion
that this case must be dismissed for lack of subject matter jurisdiction.
AFFIRMED
† In its order dismissing the complaint, the district court stated that Zhan failed
to provide information regarding “residency” to establish diversity. (Doc. 7, Order at 2.)
Residence and citizenship are not synonymous, and “it is the latter that matters for
purposes of … diversity jurisdiction.” Meyerson v. Harrah's East Chicago Casino, 299 F.3d
616, 617 (7th Cir. 2002).

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