YOUNG v. PNC BANK NATIONAL ASSOCIATION
3:16-cv-00298
| N.D. Fla. | Aug 2, 2016Background
- Plaintiff David A. Young filed a small‑claims action in Okaloosa County, Florida, alleging trespass/harm to property by PNC Bank and requesting $1.00 plus a release/satisfaction/discharge of the mortgage lien and note.
- The underlying note and mortgage principal balance is approximately $276,000.00.
- PNC removed the case to federal court, asserting diversity jurisdiction (complete diversity and amount in controversy > $75,000) and federal‑question jurisdiction.
- Plaintiff moved to remand, arguing the amount in controversy is only $1.00 and relying on various state/common‑law and nonstandard legal theories.
- The magistrate judge construed the filing as a motion to remand, considered the removal bases, and recommended denial of the motion to remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether removal under diversity jurisdiction is proper (amount in controversy) | Young: relief sought is $1.00, so amount in controversy does not exceed $75,000 | PNC: plaintiff seeks to void the mortgage lien; value of the object of litigation (mortgage interest) exceeds $75,000 | Removal under diversity is proper because the value of the object of the litigation (discharge of a $276,000 mortgage) exceeds $75,000 |
| Whether federal‑question jurisdiction supports removal | Young: complaint grounded in state/common law and nonstandard theories (challenges federal jurisdiction implicitly) | PNC: complaint references federal banking and securities law; federal question may arise | Federal‑question jurisdiction plausibly exists given plaintiff’s references to federal banking/securities law; court noted §1331 applies where action arises under federal law |
Key Cases Cited
- Ericsson GE Mobile Comm’ns, Inc. v. Motorola Comm’ns & Elecs., Inc., 120 F.3d 216 (11th Cir. 1997) (amount in controversy for injunctive relief measured by value of object of litigation)
- Hunt v. Wash. State Apple Advertising Comm’n, 432 U.S. 333 (U.S. 1977) (value of the object of litigation controls amount in controversy for equitable relief)
- Merrell Dow Pharm. Inc. v. Thompson, 478 U.S. 804 (U.S. 1986) (standards for federal‑question jurisdiction analysis)
- Jairath v. Dyer, 154 F.3d 1280 (11th Cir. 1998) (discussion of federal‑question jurisdiction principles)
- Shannon v. Enterprise Rent‑A‑Car, 279 F.3d 967 (11th Cir. 2002) (applying object‑of‑litigation rule to determine amount in controversy)