Esquilin-Mendoza v. DON KING PRODUCTIONS, INC.
2011 U.S. App. LEXIS 3410
| 1st Cir. | 2011Background
- DKP sued Puerto Rico establishments for intercepting its closed‑circuit telecast; judgment and writ of execution issued against Esquilín’s conjugal partnership entity for Delia’s Tacos; DKP’s mistaken belief about Esquilín’s surname led to naming Delia López and the conjugal partnership in the order; vehicle seized and not returned promptly after the judgment was vacated; Esquilín claimed emotional distress and loss of use worth ~$1 million; district court dismissed for lack of causation; court order vacated and suit dismissed for lack of federal jurisdiction under §1332 because amount in controversy did not reach $75,000.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal jurisdiction exists under §1332 for amount in controversy | Esquilín asserts damages exceed $75,000 | DKP argues damages cannot meet jurisdictional threshold | No jurisdiction; amount in controversy legally cannot reach $75,000 |
| Whether plaintiffs’ claim was plead in good faith and amount controls | Esquilín pleaded emotional damages in excess of threshold | Esquilín’s claims are not legally compensable; ownership issues irrelevant | Claim cannot reach jurisdictional minimum; dismissal appropriate |
| Whether the district court erred in applying St. Paul Mercury and related precedents | While good faith present, jurisdiction should lie based on alleged damages | Legal certainty shows claim cannot reach jurisdictional amount | Legal certainty test controls; lack of statutory amount defeats jurisdiction |
| Whether the injury alleged is causally linked to DKP’s seizure | Seizure caused emotional distress and loss of use | Seizure within scope of valid judgment despite naming defect | No compensable damages proven for emotional distress; only possible damages were vehicle rental value under $75,000 |
Key Cases Cited
- St. Paul Mercury Indemnity Co. v. Red Cab Co., 303 U.S. 283 (1938) (sets the amount in controversy rule and legal certainty standard for jurisdiction)
- Coventry Sewage Assoc. v. Dworkin Realty Co., 71 F.3d 1 (1st Cir.1995) (good faith in pleading jurisdiction includes an objective element)
- Barrett v. Lombardi, 239 F.3d 23 (1st Cir.2001) (amount in controversy controlled by face of pleadings if in good faith)
- Jimenez Puig v. Avis Rent-A-Car System, 574 F.2d 37 (1st Cir.1978) (clarifies good faith and jurisdictional amount inquiry)
- Spielman v. Genzyme Corp., 251 F.3d 1 (1st Cir.2001) (discusses proper standard for jurisdictional amount)
- Dep't of Recreation & Sports v. World Boxing Ass'n, 942 F.2d 84 (1st Cir.1991) (context for jurisdictional threshold analysis)
- Arbaugh v. Y & H Corp., 546 U.S. 500 (2006) (affirms federal court jurisdiction gates)