Summary
The United States District Court for the Middle District of Alabama remanded a removed state-court action involving alleged improper mortgage-account charges. The court held that the defendant failed to establish by a preponderance of the evidence that the amount in controversy exceeded the diversity-jurisdiction threshold because the claimed interest was prejudgment interest and therefore excluded from the jurisdictional calculation. The court denied pending motions as moot and terminated all pending deadlines and hearings.
Court
United States District Court for the Middle District of Alabama, Northern Division
Jurisdiction
United States District Court for the Middle District of Alabama, Northern Division
Decision date
April 6, 2026
Docket number
2:25-cv-568-ECM
Disposition
remanded
Questions Presented
- Whether the amount in controversy for diversity jurisdiction may include the interest sought by plaintiffs.
- Whether the defendant established by a preponderance of the evidence that the amount in controversy exceeded $75,000.
- Whether the case should be remanded for lack of subject matter jurisdiction.
Holdings
- The plaintiffs' requested interest was prejudgment interest arising solely from delay in payment, not interest owed as part of an underlying contractual obligation, and therefore was excluded from the amount in controversy.
- Defendant failed to show by a preponderance of the evidence that the amount in controversy exceeded $75,000.
Court Document
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