Eckerberg v. Inter-State Studio & Publishing Co., 860 F.3d 1079

Plaintiff Aaron Eckerberg, a U.S. Marine who previously declared Florida his legal residence, was injured in a February 2014 collision in Missouri caused by an Inter-State vehicle; liability was admitted and the jury awarded $4.5 million in damages after a five-day trial.
At trial Eckerberg presented economic and medical testimony showing substantial future wage losses and lasting physical and cognitive injuries; non‑economic harms (pain, suffering, family strain) were also emphasized.
Inter‑State moved post‑trial to dismiss for lack of subject‑matter jurisdiction, arguing Eckerberg had acquired Missouri domicile before filing suit; the district court held an evidentiary hearing and found Eckerberg remained domiciled in Florida.
Inter‑State also moved for remittitur, arguing the $4.5 million award was grossly excessive relative to $59,000 in medical bills and because Eckerberg remains employed by the Marines; the district court denied remittitur.
The Eighth Circuit affirmed: it deemed the district court’s domicile findings not clearly erroneous and held the damages award was supported by the evidence (both economic and non‑economic components) and not monstrously excessive.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Subject‑matter jurisdiction (domicile)	Eckerberg contends he remained domiciled in Florida (earlier signed State of Legal Residence, FL voter registration, license, bank, taxes, Fitness Reports expressing intent to return).	Inter‑State contends Eckerberg became a Missouri domiciliary before filing (Missouri licenses, vehicles titled in MO, rental home and newly purchased 40‑acre property, family supports in MO).	Court held Eckerberg remained domiciled in Florida; district court’s factual finding was not clearly erroneous, so diversity jurisdiction existed.
Remittitur (excessiveness of damages)	Eckerberg argues economic losses (lost career opportunities, diminished promotion potential) plus significant non‑economic harms justify $4.5M.	Inter‑State argues award is grossly excessive given $59K medical bills and plaintiff remains employed (undeployable ≠ unemployable).	Court held denial of remittitur was not an abuse of discretion; award was supported by economic expert testimony and non‑economic pain/suffering evidence and was not monstrous or plainly unjust.

Gunn v. Minton, 568 U.S. 251 (overview of limited federal jurisdiction)
Grupo Dataflux v. Atlas Global Grp., L.P., 541 U.S. 567 (diversity measured at time of filing)
Meléndez–García v. Sánchez, 629 F.3d 25 (1st Cir.) (servicemembers presumed to retain prior domicile absent clear, unequivocal evidence)
Ellis v. Se. Constr. Co., 260 F.2d 280 (8th Cir.) (serviceman domicile principles and weight of unequivocal testimony)
Yeldell v. Tutt, 913 F.2d 533 (8th Cir.) (elements for establishing domicile: physical presence and intent)
Hudson v. United Sys. of Ark., Inc., 709 F.3d 700 (8th Cir.) (standard for remittitur; monstrous or shocking result required)
Eich v. Board of Regents for Central Mo. State Univ., 350 F.3d 752 (8th Cir.) (deference to jury on non‑economic damages)