Angela Anders and Ruby Duncan v. William Charles Keough and Keough Hackles, LLC

Summary

The court denies the plaintiffs’ motion to remand a motor-vehicle personal-injury action removed from Illinois state court on diversity-jurisdiction grounds. It holds that the defendants presented a plausible estimate exceeding $75,000 for each plaintiff and that recovery above the jurisdictional threshold was not legally impossible because the plaintiffs had not filed a binding damages disclaimer. The court also directs the parties to confer regarding discovery and file a joint status report.

Holdings

1. The amount-in-controversy requirement was satisfied because defendants presented a plausible, good-faith estimate that each plaintiff could recover more than $75,000.
2. Plaintiffs failed to show that it was legally impossible for either plaintiff to recover more than $75,000.
3. The plaintiffs' placement in the Law Division of the Circuit Court of Cook County did not cap their potential recovery at $75,000 and therefore did not establish legal impossibility.
4. Aggregation was unnecessary because each plaintiff individually could legally recover more than $75,000.

Questions Presented

1. Whether the amount-in-controversy requirement for diversity jurisdiction was satisfied when the complaint did not specify damages and plaintiffs asserted that they sought only medical expenses below $15,000 each.
2. Whether plaintiffs established that recovery exceeding $75,000 per plaintiff was legally impossible, such that remand was required.
3. Whether a settlement-demand letter and the types of damages potentially available under Illinois law could support defendants' good-faith estimate of the amount in controversy.

Disposition

other