Wednesday, September 15, 2010

When does $74,139.24 exclusive of interest and costs exceed $75,000

In Merial Limited v. Rasnic, Judge Sargent concluded that a claim for $74,139.24 satisfied the amount in controversy requirement under 28 U.S.C. 1332, which gives the federal courts subject matter jurisdiction of certain "civil actions where the matter in controversy exceeds the sum or value of $75,000, exclusive of interest and costs."

Back when I was law clerk, Judge Williams dealt with something similar in the case of Allstate v. Brown, 736 F. Supp. 705 (W.D. 1990), where the insurer brought a declaratory judgment related to the defendant's suit in state court, in which the claim was for precisely the jurisdictional amount. Judge Williams unlike some federal judges was always a big fan of diversity cases, and decided in favor of federal court jurisdiction in the Brown case.