Robert Helton v. USAA General Indemnity Company, et al.

Summary

The United States District Court for the District of Arizona denied Robert Helton’s motion to remand his underinsured-motorist coverage, breach-of-contract, and bad-faith action against USAA General Indemnity Company. The court held that the amount in controversy exceeded $75,000 based on Helton’s pre-suit damages calculations, with potential punitive damages and attorneys’ fees providing additional support for diversity jurisdiction.

Holdings

1. The amount in controversy exceeded $75,000 because Helton's undisputed pre-suit communications established at least $198,230.42 in compensatory damages before accounting for the $100,000 paid by State Farm.
2. Prospective attorney's fees must be included in the amount-in-controversy analysis when recoverable under a statute or contract, although the court did not need to calculate them because compensatory damages alone satisfied the threshold.

Questions Presented

1. Whether USAA established by a preponderance of the evidence that more than $75,000 was in controversy for purposes of diversity jurisdiction.
2. Whether Helton's pre-suit damages demand and the damages alleged in his complaint established the amount in controversy without a detailed valuation of punitive damages or attorney's fees.

Disposition

other