Court Jurisdiction, Procedure and Review: Federal Court Jurisdiction; Amount in Controversy

摘要

The defendants remove the present quiet title lawsuit to federal court, asserting that there is diversity jurisdiction over the case. The plaintiffs only ask the court to determine the ownership of the subject mineral interest. They do not ask for a monetary judgment or consequential damages. The Userys move to remand the action back to the state district court, alleging that the amount in controversy does not exceed $75,000. The district court denies the motion. The Userys appeal. Held: reversed and remanded with directions that the district court remand the case to state court. The court notes that it is aware of cases in other circuits that hold that when the costs to a defendant of losing a case exceed the benefit that a plaintiff would gain by winning it, the amount in controversy can sometimes be measured by the defendant's costs. This court, however, finds that, in the present case, the matter in controversy is the market value of the disputed mineral interest, and that amount is, by definition, necessarily the same to both parties. The court concludes that the two affidavits from the defendants that were relied upon by the district court in denying the plaintiffs' motion to remand are insufficient in their attempts to prove the market value of the disputed mineral interest, to support the conclusion that the requisite jurisdictional amount was in controversy in this lawsuit.