Summary
The United States District Court for the Northern District of Ohio held that it lacked subject-matter jurisdiction over Jaret Paglio’s state-law claims against Reinhart University and Dr. Walter May. Although complete diversity existed, the court concluded that the amount in controversy did not exceed $75,000 because punitive damages were unavailable on the pleaded claims. The court remanded the action to the Geauga County Court of Common Pleas.
Court
United States District Court for the Northern District of Ohio
Jurisdiction
United States District Court for the Northern District of Ohio
Decision date
April 3, 2026
Docket number
1:26-cv-88
Disposition
remanded
Questions Presented
- Whether the federal court had diversity subject matter jurisdiction over the removed action.
- Whether the amount in controversy exceeded the $75,000 jurisdictional threshold under 28 U.S.C. § 1332.
- Whether punitive damages could plausibly be included in the amount in controversy based on Paglio's contract, unjust-enrichment, negligence, conversion, and tortious-interference claims.
Holdings
- Complete diversity existed because Paglio was domiciled in Ohio and both defendants were citizens of Georgia.
- The amount in controversy did not exceed $75,000, so the court lacked diversity subject matter jurisdiction.
- The case had to be remanded to the Geauga County Court of Common Pleas because the federal court lacked subject matter jurisdiction.
Court Document
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