Eli's General Contracting, LLC v. Next Insurance US Company, 1:24-cv-00090

Background

Eli’s General Contracting LLC sued Next Insurance US Company in Ohio state court concerning disputes over an insurance policy.
Eli’s complaint stated damages sought were over $25,000 but less than $75,000, including punitive damages, interest, and fees.
Next Insurance removed the case to federal court under diversity jurisdiction, asserting the amount in controversy exceeded $75,000.
After removal, Eli’s filed an unequivocal stipulation limiting total recovery to less than $75,000 and moved to remand the case back to state court.
Next Insurance argued a pre-litigation damages email created jurisdiction, claiming Eli’s true claim surpassed $75,000.
The court considered whether the stipulated damages cap was a valid clarification or an improper reduction after removal.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the amount in controversy exceed $75,000?	Eli’s never intended to exceed $75,000; stipulation clarifies this	Pre-litigation damages list exceeded $75,000, so jurisdiction proper	Stipulation is first, binding, unequivocal clarification; <$75,000
Does a pre-litigation settlement communication set the amount in controversy?	No, email not from Eli’s counsel and sought $50,000 settlement	Yes, email demonstrated intent to seek >$75,000	Email was not authoritative nor determinative
Is the post-removal stipulation valid to limit jurisdiction?	Yes, it is unequivocal, binding, and clarifies the true claim	No, it’s a reduction of an original higher amount	Stipulation is valid; deprives court of jurisdiction
Should the case be remanded to state court?	Yes, federal jurisdictional threshold not met	No, threshold was met at removal	Yes, case remanded to state court

Key Cases Cited

No official reporter-cited cases were used; all cases referenced were via district court decisions or appellate opinions lacking official reporter citations in this opinion.