Love v. G4S Secure Solutions USA, Inc., 3:17-cv-00434

Christina Love, a former employee of G4S Secure Solutions USA, alleges gender discrimination, retaliatory discharge under the Kentucky Civil Rights Act, and wrongful termination in violation of public policy for possessing a firearm while lawfully armed at work.
Love sued in Jefferson Circuit Court and G4S removed the action to federal court invoking diversity jurisdiction under 28 U.S.C. § 1332.
The parties are diverse; the only disputed jurisdictional element is whether the amount in controversy exceeds $75,000.
After removal, Love’s counsel filed a stipulation that she "will not seek a judgment or request a verdict for an amount in excess of $74,999.00" and will limit attorney’s fees so total recovery would not exceed that amount.
The Court evaluated whether a post-removal stipulation sufficiently and unequivocally limits recoverable damages to destroy federal diversity jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Love’s post-removal stipulation defeats diversity jurisdiction by keeping the amount in controversy below $75,000	Love contends her counsel’s stipulation that she will not seek or request a judgment over $74,999 prevents the amount in controversy from meeting the $75,000 threshold	G4S argues the stipulation is insufficient because post-removal reductions are generally disfavored and the stipulation is not unequivocal as to accepting or enforcing a judgment	Court denied remand: stipulation was not unequivocal because it did not state Love would neither seek nor accept damages over $75,000, so federal diversity jurisdiction remains intact

Rogers v. Wal-Mart Stores, Inc., 230 F.3d 868 (6th Cir. 2000) (post-removal stipulations lowering claimed damages do not automatically require remand)
Egan v. Premier Scales & Sys., 237 F. Supp. 2d 774 (W.D. Ky. 2002) (stipulation must unequivocally limit recoverable damages to warrant remand)