Diefenthal v. C.A.B

Brief Fact Summary.

Plaintiffs sued an airline for denying them seats in the smoking section of the flight, claiming that the flight attendant humiliated them. Plaintiffs’ complaint did not specify any physical or emotional damage to support their claim of damages.

Synopsis of Rule of Law.

Even if a plaintiff asserts a claim of damages in good faith, a plaintiff’s claim must still assert sufficient facts to support such a claim of damages to satisfy the amount in controversy requirement for diversity jurisdiction.

Facts.

Stanley and Elka Diefenthal (Plaintiffs) brought suit against Eastern Airlines (Eastern) and Civil Aeronautics Board (Defendant) after buying first class tickets on a flight to Philadelphia that were supposed to be in the smoking section and then being denied seating in that area. The flight attendant harshly told them that the smoking section was full. Plaintiffs sued Defendant on various theories and sued Eastern for breach of contract and for tortiously embarrassing and humiliating them. Eastern moved to dismiss Plaintiffs’ claims for failing to state a claim that would grant them relief. The district court dismissed the claims based on a lack of diversity jurisdiction. In regard to their breach of contract claim, the district court held that the amount of controversy could never possibly exceed the required amount of more than $10,000. In regard to their tort claim, the district court allowed Plaintiffs to amend with a warning that the amount in controversy required for diversity jurisdiction would again be a problem. Plaintiffs amended their complaint to allege that the flight attendant purposefully treated Plaintiffs in a malicious manner when denying them their right to the smoking section, which caused them embarrassment and humiliation, but failed to even state what the flight attendant had said and any physical or emotional damage. They also claimed $50,000 in damages for this claim. Eastern moved to dismiss for lack of subject matter jurisdiction, which the district court granted. The district court concluded that it was not at all possible for the Plaintiffs to recover the required amount in controversy. Plaintiffs subsequently appealed to the United States Court of Appeals for the Fifth Circuit.

Issue.

To satisfy the amount in controversy requirement for diversity jurisdiction, may a plaintiff make an unsupported claim for the required amount of damages?

Held.

No. To satisfy the amount in controversy requirement for diversity jurisdiction, a plaintiff may not make an unsupported claim for the required amount of damages. Asserting damages in good faith will generally be enough to satisfy diversity jurisdiction; however, the plaintiff’s claim must still assert enough facts to support the claim of damages. In this case, Plaintiffs made no mention of the physical or emotional damages that would support their claim for damages in both the original and amended complaints. As such, it was legally certain that Plaintiffs’ damages were not going to meet the $10,000 amount in controversy required for diversity jurisdiction to be satisfied. The United States Court of Appeals for the Fifth Circuit affirmed dismissal of Plaintiffs’ claims.

Discussion.

The reason diversity jurisdiction has an amount in controversy requirement is to prevent federal courts from hearing small claims that should be resolved in state courts. Even if Plaintiffs truly believed that they were entitled to more than $10,000 for being denied their smoking section seats, it was a legal certainty that Plaintiffs would not recover such an amount based on a lack of support for their claims. Plaintiffs are given the benefit of the doubt, but only to a certain extent. Otherwise, all plaintiffs will assert that they truly believe they deserve more than $10,000. Therefore, plaintiffs are still required to assert enough facts to support a good faith belief of damages.