Nelson v. Keefer

Brief Fact Summary.

Joined personal injury claims were dismissed as failing to meet the amount in controversy requirement when the district court determined pretrial to a legal certainty that none of the claims exceeded the required amount.

Synopsis of Rule of Law.

A court may dismiss a claim made under federal diversity jurisdiction where it determines to a legal certainty, based on the facts alleged pretrial, that no claim will meet the amount in controversy requirement.

Facts.

A husband, wife, and son (Plaintiffs) filed personal injury lawsuits in federal court, claiming jurisdiction under diversity of citizenship. The claims were joined. In a pretrial hearing the judge determined that the facts alleged by the Plaintiffs did not meet the amount in controversy requirement for any one of their claims. The claims were dismissed from federal court and Plaintiffs appealed, claiming that the dismissal pretrial violated their right to a jury trial.  

Issue.

May a court dismiss a claim based upon facts alleged pretrial for failing to meet the amount in controversy requirement without violating the plaintiff’s statutory right to a jury trial?

Held.

(Aldisert, J.) Yes. A court may dismiss a claim made under federal diversity jurisdiction where it determines to a legal certainty, based on the facts alleged pretrial, that no claim will meet the amount in controversy requirement. The plaintiff’s right to a jury trial only exists where there is a right to a trial at all in federal court. Without federal jurisdiction, there is no right to trial in a federal court. Affirmed.

Discussion.

Federal courts are courts of limited jurisdiction. A plaintiff must establish the basis for federal jurisdiction in the complaint to get the action before a federal court. The amount in controversy requirement is a mechanism for limiting the number of cases which the federal courts have to hear. This is especially important in cases falling under diversity jurisdiction where the subject matter is ordinarily not limited (with the exception of purely state questions).