Shirley Mae Graham v. Montecorp LLC, et al.

Summary

The court explains its denial of defendants’ motion to dismiss for lack of subject-matter jurisdiction in a personal-injury action arising from a motor vehicle accident. Applying the legal-certainty standard for diversity jurisdiction, the court holds that the plaintiff’s good-faith demand for more than $75,000 satisfies the amount-in-controversy requirement.

Holdings

1. The amount in controversy was satisfied because Graham's complaint alleged in good faith that her damages exceeded $75,000 and sought damages that could exceed that amount.
2. Defendants did not show to a legal certainty that Graham could not recover more than $75,000, so dismissal for lack of subject-matter jurisdiction was unwarranted.

Questions Presented

1. Whether the amount-in-controversy requirement for diversity jurisdiction was satisfied when the complaint alleged in good faith that damages exceeded $75,000 and sought compensatory, punitive, and other damages, despite a pre-suit letter identifying $12,597.40 in special damages.
2. Whether the defendants established to a legal certainty that Graham could not recover more than $75,000.

Disposition

other