Plaintiff, Burns, was involved in an auto accident with defendant, Anderson. Burns’ principal injury was a broken thumb. Burns claimed $1,026 for lost wages and medical bills and $60,000 for pain and suffering.
Procedural History
The District Court for the Eastern District of Louisiana dismissed the case for want of jurisdiction to which plaintiff appealed. The Appeals Court found that Burns’ disability was very minimal with the total medical bills being $250 and the total lost wages less than $300, which fell below the $10,000 minimum.
Issue(s)
May a district court dismiss a personal injury diversity suit where it appears the claim was really for less than the jurisdictional amount?
Holding(s)
Yes.
Reasoning/Analysis
The court found that the determinant is plaintiff's good faith claim and that to justify dismissal it must appear to a legal certainty that the claim is really for less than the jurisdictional amount and, once it is clear that as a matter of law the claim is for less than $10,000.00, the Trial Judge is required to dismiss. The court felt that Burns’ actions spoke louder than his words in the very short amount of time for his disability and taking a job as a carpenter’s assistant approximately one month after the accident. Even if the case had gone to trial and the jury returned a verdict in excess of $10,000, the judge would have been compelled as a matter of law to order a remittitur.
Judgment/Outcome
The court affirmed the decisions of the district and appellate courts.
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