David Johnson v. Tractor Supply Company

Summary

The United States District Court for the Middle District of Florida remands the case to state court after Tractor Supply Company failed to establish by a preponderance of the evidence that the amount-in-controversy requirement for diversity jurisdiction was satisfied. The court holds that it may independently question jurisdiction and require supporting evidence when a removal notice relies on conclusory allegations. It concludes that the plaintiff’s settlement proposal, standing alone, does not establish the jurisdictional amount.

Holdings

1. A federal district court may, and has an independent obligation to, question conclusory jurisdictional allegations and require a removing defendant to demonstrate that the jurisdictional threshold is satisfied, even when the plaintiff has not moved to remand.
2. Once the court questions the amount-in-controversy allegation, the removing defendant must establish the jurisdictional amount by a preponderance of the evidence; the lenient pleading standard for an initial notice of removal is no longer sufficient.
3. A settlement demand, standing alone and without supporting factual evidence, does not establish that the amount in controversy exceeds the jurisdictional threshold.

Questions Presented

1. Whether a federal district court may sua sponte inquire into the factual basis for diversity jurisdiction and require a removing defendant to establish the amount in controversy.
2. Whether, after the court questions the jurisdictional allegations, the removing defendant must prove the amount in controversy by a preponderance of the evidence rather than rely on a short and plain statement in the notice of removal.
3. Whether a plaintiff's unsupported proposal for settlement, standing alone, establishes the amount in controversy for diversity jurisdiction.

Disposition

remanded