SAUNDERS v. ESURANCE INSURANCE SERVICES INC.
1:23-cv-00368
| W.D. Pa. | May 8, 2024Background
- Natasha Saunders sued Esurance Insurance Services (an Allstate company) in Pennsylvania state court, alleging breach of contract and statutory bad faith regarding a dispute over motor vehicle storage fees, rental car fees, and repair estimates.
- The complaint did not specify an exact amount of damages, only referencing damages to be proven at trial and general categories of relief.
- Esurance removed the case to federal court, asserting diversity jurisdiction and that the amount in controversy exceeded $75,000.
- Saunders sought remand to state court, arguing that the amount in controversy requirement had not been met.
- The parties agreed on diversity but disputed whether the jurisdictional monetary threshold for federal court was satisfied.
- The court was also asked to consider whether Saunders should be awarded attorney fees and expenses for costs of removal.
Issues
| Issue | Saunders' Argument | Esurance's Argument | Held |
|---|---|---|---|
| Proper amount in controversy for federal removal | Did not allege a specific amount; argues threshold is not met | Because damages could be over $50,000 and include punitive damages, threshold is met | Amount not met; remand granted |
| Effect of arbitration limit exceeded in complaint | Checking 'outside arbitration limits' is mere boilerplate | Indicates damages are over $50,000; punitive/fees likely bring it over $75,000 | Does not prove over $75k; too speculative |
| Refusal to stipulate damages below $75,000 | Not required to stipulate; irrelevant to federal jurisdiction | Refusal implies damages could exceed jurisdictional amount | Stipulation refusal has little bearing |
| Attorney fees for improper removal | Removal was baseless, should get fees/costs | Had an objectively reasonable basis for removal | Defendant had a reasonable basis; no fees |
Key Cases Cited
- Brown v. Jevic, 575 F.3d 322 (3d Cir. 2009) (removing party bears heavy burden to show proper federal jurisdiction)
- Frederico v. Home Depot, 507 F.3d 188 (3d Cir. 2007) (punitive damages can be counted for jurisdictional amount)
- Johnson v. SmithKline Beecham Corp., 724 F.3d 337 (3d Cir. 2013) (removal doubts resolved in favor of remand)
- Angus v. Shiley, Inc., 989 F.2d 142 (3d Cir. 1993) (court assesses a reasonable reading of claim value for jurisdiction)