Willis v. Huck, 5:24-cv-00573

Plaintiff Tommy Willis, a Texas resident and entertainment promoter, sued Tim Huck and ALB Ventures, LLC (operators of a Shreveport nightclub) in federal court, originally alleging defamation and intentional infliction of emotional distress (IIED).
Willis's claims stem from a late-night payment dispute, during which he alleges Huck pulled a gun, threatened him, and later made false statements to police that were published in the media.
Willis claimed these alleged actions resulted in personal, professional, and economic harm, including leaving the entertainment business, and sought $10 million in damages.
After amending his complaint multiple times, Willis added ALB Ventures, LLC, and a claim for negligent infliction of emotional distress (NIED), and dropped a prior defendant.
Huck and ALB Ventures moved to dismiss under Rule 12(b)(1) for lack of subject matter jurisdiction, arguing the complaint failed to adequately allege damages exceeding $75,000.
The court held that Willis's alleged damages were too vague and conclusory to meet the federal amount-in-controversy threshold, compared to more particularized claims in precedent cases, and dismissed the case without prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Amount in controversy requirement met?	Willis alleges serious harm; loss is self-evidently above $75,000.	Damages claimed are vague, conclusory, unsupported by detail.	Plaintiff failed to show by a preponderance of evidence; threshold not met.
Specificity of damages pleaded	Willis alleges professional, economic, and emotional harm.	No itemized amounts or details—only broad, general assertions.	Allegations were insufficiently specific to satisfy jurisdiction.
Applicability of Luckett v. Delta Airlines	Willis’s damages are sufficiently analogous to those in Luckett (pain, loss).	Luckett had far more detailed damages than Willis here.	Plaintiff’s damages not as detailed as Luckett; Luckett not controlling.
Consideration of comparable case law	Serious and dangerous conduct warrants higher damages even if not itemized.	Cites Hanson, where dismissal was denied due to specific proof.	No comparable detail or proof as in Hanson; court dismisses claim.

St. Paul Reinsurance Co., Ltd. v. Greenberg, 134 F.3d 1250 (5th Cir. 1998) (sets out test for determining whether the amount in controversy meets the jurisdictional minimum, focusing on complaint specificity)
Luckett v. Delta Airlines, Inc., 171 F.3d 295 (5th Cir. 1999) (district court may find amount in controversy satisfied when detailed damages alleged)
Allen v. R & H Oil & Gas Co., 63 F.3d 1326 (5th Cir. 1995) (party invoking federal jurisdiction must establish the amount by a preponderance of the evidence)
Ramming v. United States, 281 F.3d 158 (5th Cir. 2001) (12(b)(1) dismissal standard for lack of subject matter jurisdiction)