Rosa Estela Saucedo Serna v. Target Corporation

Summary

The United States District Court for the Central District of California remanded this premises-liability and negligence action to state court for lack of subject matter jurisdiction. The court held that Defendant failed to establish by a preponderance of the evidence that the amount in controversy exceeded $75,000 because Plaintiff's $10 million general-damages demand was an unsupported optimistic prediction and the remaining $49,909 in special damages was insufficient.

Holdings

1. A damages statement does not establish the amount in controversy when it is unsupported by specific facts and appears to be only a bold optimistic prediction rather than a reasonable estimate of the plaintiff's claims.
2. Defendant failed to establish by a preponderance of the evidence that the amount in controversy exceeded $75,000, so the federal court lacked subject matter jurisdiction and was required to remand the action.

Questions Presented

1. Whether Defendant established by a preponderance of the evidence that the amount in controversy exceeded $75,000 for purposes of diversity jurisdiction under 28 U.S.C. § 1332.
2. Whether Plaintiff's $10 million general-damages demand constituted a reasonable estimate of the amount in controversy or merely a bold optimistic prediction.

Disposition

remanded