Wednesday, December 29, 2021

Judge Robert D. Mariani of Federal Middle District Court Addresses Motion for Remand

In the case of Miller v. State Farm Mut. Auto. Ins. Co., No. 3:21-CV-1433-RDM (M.D. Pa. Dec. 14, 2021 Mariani, J.), the court granted a Plaintiff’s Motion to Remand a UIM breach of contract case back to the Lackawanna County Court of Common Pleas.

In this matter, the Plaintiff had UIM coverage with State Farm in the amount of $25,000.00 per person. In her Complaint, the Plaintiff demanded judgment against State Farm in an amount in excess of $50,000.00 plus interest, costs, and other such relief the court may deem appropriate. 

With her Motion for Remand, the Plaintiff asserted that the amount in controversy did not exceed the federal jurisdiction limit of $75,000.00 and that, as such, the action must be remanded to the state Court of Common Pleas.

Judge Mariani reviewed the removal statute and noted that this statute was required to be strictly construed, with all doubts to be resolved in favor of a remand.

The court additionally noted that the test for determining whether a case involved the requisite federal jurisdictional amount is whether, from the allegations in the pleadings, it is apparent, “to a legal certainty” that the Plaintiff cannot recover the amount claimed, or if, from the proofs, the court is satisfied to a like certainty that the Plaintiff never was entitled to recover that amount. See Op. at 3-4.

Judge Mariani also noted that the United States Supreme Court has long held that Plaintiffs may limit their claims in order to avoid federal subject matter jurisdiction. 

Moreover, where a Plaintiff has not specifically alleged in the Complaint that the amount in controversy is less than the jurisdictional minimum, the case must still be remanded if it appears to a legal certainty that the Plaintiff cannot recover the jurisdictional amount.

The court also noted that, where a Complaint does not limit its request for damages to a precise monetary amount, the District Court must make an independent appraisal of the potential value of the claim.

Judge Robert D. Mariani

Judge Mariani noted that it was alleged in the Complaint that the Plaintiff’s UIM policy provided UIM benefits in the amount of $25,000.00 per person. The court also emphasized that there was no companion claim for bad faith or punitive damages asserted in the Complaint. It was additionally noted that, relative to this Motion for Remand, the Plaintiff conceded that the Defendant’s only exposure was to $25,000.00 UIM policy limits.

The court rejected the defense argument that federal court jurisdiction had been met under the analysis that the tortfeasor had $100,000.00 in liability coverage which required the Plaintiff to prove her damages were in excess of that liability coverage in order to gain access to the UIM benefits, which necessarily placed the amount in controversy above the $75,000.00 jurisdictional requirement.

Judge Mariani stated that there was no case law in support of this argument. The court reiterated that the Plaintiff’s breach of contract recovery was restricted to the $25,000.00 limits set forth in her State Farm policy.

As such, where the court deemed that it appeared to a “legal certainty” that the Plaintiff could not recover the jurisdictional amount necessary to confer subject matter jurisdiction on this federal court, and given that the federal court is required to strictly construe removal statutes with all doubts to be resolved in favor of a remand, the decision was made to remand the case to the Lackawanna County Court of Common Pleas.

In a footnote at the end of his decision, Judge Mariani again emphasized “the importance of the fact that Plaintiff’s Complaint only alleges a claim for underinsured motorist benefits/breach of contract.”  See Op. at p. 7, fn.3. In that same footnote, Judge Mariani stated that, “[i]f Plaintiff had included a claim for bad faith, the Court would find that remand was not appropriate.” Id.

Anyone wishing to review a copy of this decision may click this LINK.

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