Eminent Consulting, LLC v. RightSourcing, Inc.

Summary

The United States District Court for the Eastern District of California granted Eminent Consulting, LLC’s motion to dismiss RightSourcing, Inc.’s counterclaim for lack of subject matter jurisdiction. The court concluded that the counterclaim did not satisfy the amount-in-controversy requirement for diversity jurisdiction and did not share a common nucleus of operative fact with the complaint for purposes of supplemental jurisdiction. Dismissal was granted with leave to amend within twenty days.

Holdings

1. The counterclaim did not establish original diversity jurisdiction because it alleged only $65,000 in damages, which was below the $75,000 amount-in-controversy requirement, and the pleading made clear that no other source of damages was alleged.
2. The court lacked supplemental jurisdiction over the counterclaim because the complaint and counterclaim did not share a common nucleus of operative fact and therefore were not part of the same Article III case or controversy.
3. Leave to amend was warranted because RightSourcing might be able to plead additional facts establishing diversity or supplemental jurisdiction, and there was no showing of undue delay, bad faith, prejudice, or futility.

Questions Presented

1. Whether the counterclaim satisfied the amount-in-controversy requirement for diversity jurisdiction under 28 U.S.C. § 1332(a)(1).
2. Whether the counterclaim fell within the court's supplemental jurisdiction under 28 U.S.C. § 1367(a) because it shared a common nucleus of operative fact with the complaint.
3. Whether RightSourcing should be granted leave to amend its counterclaim to plead additional allegations establishing subject matter jurisdiction.

Disposition

other