Baker v. Keck

Brief Fact Summary.

Baker (Plaintiff) sued Keck (Defendant) and others in federal court in Illinois. Plaintiff’s basis for federal jurisdiction was in diversity as a resident of Oklahoma. Defendant challenged Plaintiff’s Oklahoma citizenship in Oklahoma.

Synopsis of Rule of Law.

Citizenship is determined by evidence of an individual’s intent to establish a permanent or indefinite domicile in a particular state, even if a reason for the move was to establish diversity of citizenship for federal jurisdiction.

Facts.

A dispute existed between the United Mine Workers and the Progressive Miners of America (Defendant). Plaintiff aligned with the United Mine Workers and ultimately was involved in an incident that led to the loss of his arm. Plaintiff sued Keck and others over the injury. At the time of the incident, Plaintiff was a farmer in Illinois. Shortly after the injury, he moved to Oklahoma and rented a house and farm. Plaintiff registered to vote in Oklahoma. There was evidence that the United Mine Workers had paid Plaintiff’s relocation expenses and some witnesses claimed that Plaintiff told them he would return to Illinois after the litigation was complete. Defendants alleged that Plaintiff removed to Oklahoma solely to establish federal jurisdiction for this claim. 

Issue.

Is citizenship in a state determined by evidence of an individual’s intent to establish a permanent or indefinite domicile in a particular state?

Held.

(Lindley, J.) Yes. Citizenship is determined by evidence of an individual’s intent to establish a permanent or indefinite domicile in a particular state, even if a reason for the move was to establish diversity of citizenship for federal jurisdiction. Citizenship is established by presence in a state and the intention to establish a permanent or indefinite domicile there. Even when a reason for the change in domicile is to create diversity of citizenship, if evidence of the proper intent is produced, a finding of citizenship is not precluded. Evidence of involvement in the affairs of the new state, such as voting, is a strong indicator of such intent. Plaintiff registered to vote and became involved in a community project in Oklahoma. Plaintiff established himself as a citizen of Oklahoma regardless of whether the United Mine Workers paid his expenses or a reason for the move was to establish diversity of citizenship. Motion to dismiss for lack of jurisdiction denied.

Discussion.

Federal jurisdiction extends to cases where the parties are residents of different states. The action may initially be brought in state court and then removed to federal court by the defendant. Diversity jurisdiction in federal court allows the action to be litigated without the influences of an adversary’s state court system.