Midwest Container & Industrial Supply Co. v. Hub Plastics-Midwest, LLC

Summary

The United States District Court for the Eastern District of Missouri granted Plaintiff’s motion to remand an unlawful detainer action to the Jefferson County Circuit Court. The court held that the removing defendant failed to establish by a preponderance of the evidence that the amount in controversy exceeded $75,000 for diversity jurisdiction. The plaintiff’s binding post-removal stipulation clarified that it would not seek more than the jurisdictional threshold.

Holdings

1. The removing defendant failed to establish by a preponderance of the evidence that the amount in controversy exceeded $75,000 at the time of removal; therefore, the federal court lacked original diversity jurisdiction.
2. Because the action was not within the federal court's original jurisdiction, the court was required to remand it to the state court from which it was removed.

Questions Presented

1. Whether the defendant established by a preponderance of the evidence that the amount in controversy exceeded $75,000 at the time of removal, thereby establishing diversity jurisdiction.
2. Whether the plaintiff's post-removal stipulation clarified the amount sought in the original petition and established to a legal certainty that the plaintiff could not recover more than $75,000.
3. Whether the action should be remanded to the Jefferson County Circuit Court.

Disposition

remanded