Dennis Black and Trina Black v. State Farm Fire and Casualty Company

Summary

The United States District Court for the Southern District of Indiana denied Plaintiffs' motion to remand an insurance coverage dispute removed from state court on diversity jurisdiction grounds. The court held that the 30-day removal period did not begin when the complaint was filed because the complaint did not specify an amount in controversy exceeding $75,000. The removal was timely because Plaintiffs' counsel first affirmatively and unambiguously confirmed on July 29, 2025, that Plaintiffs sought more than $100,000 in damages, and Defendant removed the case the following day.

Holdings

1. The thirty-day removal period does not begin until the defendant receives a pleading or other paper that affirmatively and unambiguously specifies a damages amount sufficient to satisfy the federal jurisdictional minimum.
2. A defendant's subjective knowledge, independent investigation, or possession of pre-litigation information does not trigger the thirty-day removal deadline when the complaint or other post-complaint paper does not affirmatively and unambiguously disclose the jurisdictional amount.
3. State Farm's July 30, 2025 notice of removal was timely because the thirty-day period began on July 29, 2025, when Plaintiffs' counsel confirmed that the amount in controversy exceeded $75,000.

Questions Presented

1. Whether the thirty-day removal period began when State Farm received the state-court complaint, despite the complaint's failure to specify the amount in controversy.
2. Whether a pre-litigation repair estimate known to State Farm triggered the removal deadline.
3. Whether State Farm's July 30, 2025 removal was timely after Plaintiffs' counsel disclosed on July 29 that damages exceeded $100,000.

Disposition

remanded