Marcy Kamin v. SN Servicing Corporation

Summary

This is a federal court order granting a plaintiff's motion to remand a putative class action lawsuit to state court. The court found that the defendant, SN Servicing Corporation, failed to meet its burden of proving the amount in controversy exceeded the $75,000 diversity jurisdiction threshold, as it improperly attempted to aggregate statutory damages from the entire class to meet the requirement for the named plaintiff alone.

Holdings

1. Complete diversity existed because SN Servicing was an Alaskan corporation with its principal place of business in Louisiana, while Kamin was a citizen of Maine.
2. The removing defendant did not establish by a preponderance of the evidence that the amount in controversy exceeded $75,000.
3. Because SN Servicing failed to establish the amount-in-controversy requirement, the court lacked subject-matter jurisdiction and was required to remand the case to state court.

Questions Presented

1. Whether the federal court had diversity subject-matter jurisdiction over the removed putative class action.
2. Whether SN Servicing established by a preponderance of the evidence that the amount in controversy attributable to the named plaintiff exceeded $75,000.
3. Whether statutory class-member damages under 32 M.R.S. § 11054(1)(C) could be attributed to the named plaintiff for purposes of satisfying the amount-in-controversy requirement.

Disposition

remanded