Davis v. Ruston Louisiana Hospital Co L L C, 3:16-cv-01316

Davis filed a civil action in 2016 in this district against NLMC asserting diversity jurisdiction under 28 U.S.C. § 1332.
Plaintiff alleged August 26, 2015 elevator door malfunction at NLMC caused serious injuries and sought various damages.
Plaintiff claimed damages exceeded the jurisdictional minimum for diversity, prompting initial assessment of complete diversity.
NLMC moved on November 22, 2017 to dismiss for lack of subject matter jurisdiction, arguing the amount in controversy was below $75,000; plaintiff did not respond.
Magistrate Judge applied the St. Paul Mercury framework and found, based on unrebutted evidence, that the amount in controversy could not exceed $75,000.
Recommend dismissal without prejudice; plaintiff may re-file in state court to avoid prescription issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the amount in controversy satisfies § 1332(a) threshold	Davis claimed damages exceed $75,000	NLMC contends damages do not exceed $75,000	No jurisdiction; amount in controversy not at jurisdictional level

St. Paul Mercury Indem. Co. v. Red Cab Co., 303 U.S. 283 (Sup. Ct. 1938) (claims presumed in good faith unless legally certain to be otherwise)
Gunn v. Minton, 568 U.S. 251 (Sup. Ct. 2013) (limited jurisdiction and burden on party invoking federal courts)
Coury v. Prot, 85 F.3d 244 (5th Cir. 1996) (presumption against subject-matter jurisdiction)
Howery v. Allstate Ins. Co., 243 F.3d 912 (5th Cir. 2001) (lack of subject matter jurisdiction may be raised at any time)
Venable v. Louisiana Workers' Comp. Corp., 740 F.3d 937 (5th Cir. 2013) (court may dismiss where plaintiff cannot plausibly establish jurisdiction)
Home Builders Ass'n of Miss., Inc. v. City of Madison, 143 F.3d 1006 (5th Cir. 1998) (principles for dismissal due to lack of jurisdiction)