Griffin v. Lee

Brief Fact Summary.

Griffin, represented by Lee,  brought an action seeking reformation of a trust and damages against the trust’s corporate trustee and its officers. Defendants removed the case to federal court based on diversity.  After Lee was allowed to withdraw as Griffin’s counsel, he moved to intervene as a party in the case to recover his attorney’s fees. The district court allowed the intervention and Lee was awarded recovery of the attorney’s fees by the district court. Griffin disputed the fee award. The Court of Appeals raised for itself the issue of whether the district court had subject matter jurisdiction over the claim for attorney’s fees.

Synopsis of Rule of Law.

Lack of complete diversity and presence of an amount in controversy of less than $75,000 are inconsistent with the requirements of 28 U.S.C. section 1332 and, therefore, will impede supplemental jurisdiction over a claim by a person seeking to intervene under Federal Rule of Civil Procedure 24.

Facts.

Griffin, represented by Lee,  brought a Louisiana state court action seeking reformation of a trust and damages due to fraud against the trust’s corporate trustee and its officers. Griffin was a Mississippi citizen; Lee was a Louisiana citizen. Defendants removed the case to federal court based on diversity.  (The corporate defendants were citizens of Delaware New York and Ohio; the individual defendants were Louisiana citizens). After Lee was allowed to withdraw as Griffin’s counsel, he moved to intervene as a party in the case to recover his attorney’s fees. The district court allowed the intervention and Lee was awarded $16,000 in attorney’s fees on his claim for approximately $54,000 by the district court after a bench trial. Griffin disputed the fee award. The Court of Appeals raised for itself the issue of whether the district court had jurisdiction over the claim for attorney’s fees.

Issue.

Did the district court properly exercise supplemental jurisdiction over Lee’s claim in intervention pursuant to 28 U.S.C. section 1367(b)?

Held.

No. The district court did not have supplemental jurisdiction over Lee’s claim in intervention.

Discussion.

The court found that 28 U.S.C. section 1367 was applicable to Lee’s claim in intervention, and that there was no supplemental jurisdiction over Lee’s claim in intervention under section 1367(b) due to a lack of complete diversity of the parties and an amount in controversy less than $75,000.