Erika Jacobs v. Geisinger Wyoming Medical Cent
21-3362
| 3rd Cir. | May 18, 2022Background:
- Pro se plaintiff Erika Jacobs sued Geisinger Wyoming Valley Medical Center in the Middle District of Pennsylvania in May 2021 for defamation, breach of contract, and wrongful termination.
- Jacobs alleged Geisinger offered her a Medical Technologist position in March 2021, she relocated from Colorado to Pennsylvania in reliance on the offer, and Geisinger later rescinded the offer claiming she failed onboarding requirements.
- Geisinger moved to dismiss partly on grounds that the District Court lacked subject-matter jurisdiction (diversity jurisdiction and amount-in-controversy shortfall).
- The complaint itemized damages totaling $20,161.78 but also included a prayer stating damages would be “no more than $75,000.”
- A Magistrate Judge recommended dismissal for lack of jurisdiction; the District Court adopted the recommendation and dismissed without prejudice.
- Jacobs’ attempts to invoke federal-question jurisdiction via definitional federal statutes (and a §1985 theory raised on appeal) were rejected as inapplicable or unpreserved.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Amount in controversy (diversity) | Jacobs: jury could award compensatory and punitive damages exceeding $75,000 | Geisinger: complaint lists ~$20,162 and expressly limits total to “no more than $75,000” | Court: amount-in-controversy not satisfied; diversity jurisdiction lacking |
| Diversity of citizenship | Jacobs: relocation creates ambiguity about domicile | Geisinger: parties are diverse (Jacobs Colorado; Geisinger Pennsylvania) | Court: no clear error in finding diversity, but jurisdiction still fails for amount shortfall |
| Federal-question jurisdiction | Jacobs: cited federal definitional statutes and referenced §1985 to invoke federal jurisdiction | Geisinger: cited statutes do not create causes of action; §1985 argument not preserved | Court: statutes cited are irrelevant to her claims; no federal-question jurisdiction; §1985 waived on appeal |
| Punitive damages as bridge to jurisdiction | Jacobs: punitive damages could push recovery over $75,000 | Geisinger: punitive damages are unsupported and unlikely under pleaded claims | Court: complaint fails to allege entitlement to punitive damages sufficient to meet jurisdictional threshold |
Key Cases Cited
- Metro. Life Ins. Co. v. Price, 501 F.3d 271 (3d Cir. 2007) (de novo review of dismissal for lack of subject-matter jurisdiction)
- Erickson v. Pardus, 551 U.S. 89 (2007) (pro se complaints must be liberally construed)
- Auto-Owners Ins. Co. v. Stevens & Ricci Inc., 835 F.3d 388 (3d Cir. 2016) (plaintiff bears burden to prove amount in controversy; amount measured at filing)
- St. Paul Mercury Indem. Co. v. Red Cab Co., 303 U.S. 283 (1938) (plaintiff's good-faith claim controls unless it is legally certain the claim is for less)
- Gertz v. Robert Welch, Inc., 418 U.S. 323 (1974) (private defamation plaintiff cannot recover punitive damages absent actual malice)
- DiGregorio v. Keystone Health Plan East, 840 A.2d 361 (Pa. Super. Ct. 2003) (punitive damages not recoverable for breach of contract)
- Mejia-Castanon v. Attorney General, 931 F.3d 224 (3d Cir. 2019) (statutory text must be read in context within the statutory scheme)
- Simko v. U.S. Steel Corp., 992 F.3d 198 (3d Cir. 2021) (arguments raised first on appeal are generally not preserved)
- N.J. Physicians, Inc. v. President of U.S., 653 F.3d 234 (3d Cir. 2011) (dismissal for lack of subject-matter jurisdiction is without prejudice)