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Federal Court Jurisdiction
Subject Matter Jurisdiction-Amount In Controversy

 

 

Subject matter jurisdiction-amount in controversy
(CAPITOL INDEM. CORP. v. 1405 ASSOCS., INC.02-3406-08/15/03)

 

Court: U.S. 8th Circuit Court of Appeals
Topic: Civil Procedure, Insurance Law, Labor & Employment Law
Title: CAPITOL INDEM. CORP. v. 1405 ASSOCS., INC
Date: 08/15/03
Case Number: 02-3406
Summary:

I.

Appellant Bajwa is the president of 1405, a corporation that owns and operates a residential property known as the Ford Hotel ("Hotel"). Capitol provides commercial insurance to 1405. On September 11, 2000, the Hotel's manager, ReginaDelaney ("Delaney"), left her employment at the Hotel. Bajwa and 1405 subsequently reported to the authorities that Delaney had failed to turn over all of the rent receipts she collected prior to her departure. Delaney was arrested based on these allegations.

After her arrest, Delaney filed a state court action against Bajwa and 1405 alleging, inter alia, false arrest, false imprisonment, unjust enrichment, wrongful termination, slander, and violations of the Fair Labor Standards Act ("FLSA"). Capitol undertook Bajwa's and 1405's defense, but reserved a right to disclaim coverage.

Capitol then filed an action in the district court seeking a declaration that it had no duty to defend or indemnify 1405 or Bajwa with regard to Delaney's suit. Finding that policy exclusions barred coverage, the district court granted summary judgment for Capitol. Bajwa and 1405 appeal, claiming that the district court (1) lacked subject matter jurisdiction because the complaint failed to specify the amount in controversy, and (2) erred in granting summary judgment based on policy exclusions.2 Capitol is a Wisconsin corporation with its principal place of business in Wisconsin. Appellant 1405 is a Missouri corporation with its principal place of business in Missouri, and Bajwa is a Missouri citizen. As such, complete diversity of citizenship exists between the parties.

II.

First, we must determine if the district court had jurisdiction to hear Capitol's action for declaratory judgment. A "complaint that alleges the jurisdictional amount in good faith will suffice to confer jurisdiction, but the complaint will be dismissed if it appear[s]to a legal certainty that the claim is really for less than the jurisdictional amount." Kopp v. Kopp, 280 F.3d 883, 884 (8th Cir. 2002) (citation and quotations omitted).

When the parties to an action are citizens of different states, as they are here,2 a district court has original subject matter jurisdiction "where the matter in controversy exceeds the sum or value of $75,000, exclusive of interest and costs." 28 U.S.C. § 1332(a). This amount-in-controversy requirement is satisfied "when a fact finder could legally conclude, from the pleadings and the proof adduced to the court before trial, that the damages that the plaintiff suffered are greater than $75,000." Kopp, 280 F.3d at 885.

Bajwa and 1405 claim that the district court lacked subject matter jurisdiction because Capitol's complaint failed to specify that the amount in controversy exceeded the $75,000 minimum required for diversity jurisdiction. We disagree. In its Supplemental Complaint for Declaratory Judgment, which governs this claim, and the attached Second Amended Petition, Capitol alleges the following damages: (1) "approximately $20,000" for unjust enrichment; (2) $43,673.49, exclusive of interest, for FLSA violations; and (3) $25,000 in compensatory damages and $25,000 in punitive damages for false arrest. These alleged damages total $113,673.49. This number exceeds the jurisdictional requirement of $75,000. Therefore, we find that the district court did have subject matter jurisdiction over Capitol's action.

District court had subject matter jurisdiction as amount in controversy exceeded the $75,000 minimum for diversity jurisdiction; insurer had no obligation to defend suit under a general liability policy, as claims were excluded by the policy's employment-related practices exclusion.

CAPITOL INDEM. CORP. v. 1405 ASSOCS., INC.02-340608/15/03

 

 

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Federal Court Basics-Table of Contents    
Federal Court Jurisdiction-Table of Contents       
Part 003-Map: Geographical boundaries of U.S. Courts of Appeals and U.S. District Courts-pdf  
CAPITOL INDEM. CORP. v. 1405 ASSOCS., INC-FL-pdf

 


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