WM Mobile Bay Environmental Center, Inc. v. The City of Mobile Solid Waste Authority
672 F. App'x 931
| 11th Cir. | 2016Background
- WM Mobile Bay Environmental Center, Inc. sued the City of Mobile Solid Waste Authority (the Authority) on multiple breach-of-contract claims and sought a declaratory judgment; after a jury trial the district court entered judgments for WM Mobile on several counts (money damages totaling several million dollars and a future disposal rate of $25.43/ton).
- The Authority appealed challenging jurisdictional facts, several contract-dispute rulings, evidentiary rulings on lost-profits proof, alleged bad faith, and the district court’s authority to set a future rate.
- The Second Amended Complaint alleged WM Mobile was incorporated in Delaware with its principal place of business in Madison, Mississippi; the Authority admitted those allegations in its answer.
- On appeal the Authority for the first time argued the record showed WM Mobile’s principal place of business was in Alabama (which would defeat diversity jurisdiction) and also argued it was an arm of the State of Alabama (i.e., not a citizen).
- The court held the Authority was bound by its prior factual admissions establishing diversity and, separately, that under the Coastal Petroleum framework the Authority is not an arm of the state but an independent public corporation; accordingly federal diversity jurisdiction was proper.
- The Eleventh Circuit affirmed the district court’s judgments on all issues; only the jurisdictional admission and arm-of-state analysis required extended discussion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Diversity jurisdiction / corporate citizenship | WM Mobile: incorporated in DE, principal place MS (as alleged in complaint) | Authority: record implies WM Mobile’s principal place is in AL, destroying diversity | Held: Authority admitted facts in its answer; admissions bind it — diversity exists and was properly relied on |
| Whether Authority is an "arm of the state" for §1332 citizenship purposes | WM Mobile: Authority is an independent public corporation and a citizen | Authority: claimed state character such that it is not a citizen of Alabama | Held: Under Coastal Petroleum factors Authority is not an arm of the state; it is a citizen for diversity purposes |
| Contract requirements for rate changes / reimbursement claims | WM Mobile: contractual triggers for adjustments and reimbursements were satisfied and damages awarded by jury | Authority: challenged sufficiency of evidence and legal entitlement to those awards | Held: Court affirmed district court and jury findings; Authority’s challenges lack merit |
| Trial evidence on lost profits and district court setting future rate | WM Mobile: presented evidence supporting lost-profits award and sought declaratory future rate | Authority: argued district court lacked authority to set a new disposal rate and certain lost-profits evidence should be excluded | Held: Appeals rejected these arguments; district court was authorized to set rate and evidentiary rulings were affirmed |
Key Cases Cited
- Ry. Co. v. Ramsey, 89 U.S. 322 (establishing that parties may admit facts showing jurisdiction and courts may rely on those admissions)
- Cooper v. Meridian Yachts, Ltd., 575 F.3d 1151 (11th Cir.) (parties are generally bound by admissions about principal place of business)
- In re CP Ships Ltd. Sec. Litig., 578 F.3d 1306 (11th Cir.) (factual challenges to jurisdiction waived when parties admitted jurisdictional facts below)
- Coastal Petroleum Co. v. U.S.S. Agri-Chemicals, 695 F.2d 1314 (11th Cir.) (framework for determining whether an entity is an arm of the state)
- Morrison v. Nat’l Austl. Bank Ltd., 561 U.S. 247 (U.S.) (noted for limited abrogation of precedent cited in jurisdictional-admission context)