Court: District Court, D. Connecticut; January 3, 2016; Federal District Court
The court dismissed the plaintiff's diversity action due to lack of subject matter jurisdiction, finding that the plaintiff, a citizen of Connecticut, failed to meet the minimum amount in controversy of $75,000 required under 28 U.S.C. § 1332. The initial complaint sought damages over $10,000, prompting the court to request evidence of a claim exceeding $75,000. The plaintiff amended his complaint to allege $110,000 in damages, detailing his purchase of a travel insurance policy and subsequent travel to London, where he was detained and allegedly tortured. He claimed damages for trip expenses, a damaged laptop, and lodging, totaling approximately $3,873, but lacked documentation for a claimed lost employment opportunity in North Korea that he estimated would yield $100,000. The court emphasized that federal diversity jurisdiction requires the amount in controversy to be assessed at the time of filing and based on the actual dollar amount claimed.
A federal court complaint must allege facts in a non-conclusory manner that plausibly establish grounds for relief, as clarified by the Supreme Court in cases like *Iqbal* and *Twombly*. Pro se complaints are to be read liberally, but they still must meet the "plausibility" threshold, as affirmed by the Second Circuit in *Fowlkes*. The plausibility standard applies not only to substantive claims but also to factual allegations supporting federal subject matter jurisdiction, including the amount in controversy for diversity jurisdiction, as suggested in *Wood v. Maguire Automotive*. Some scholars argue that this standard should not apply to jurisdictional allegations; however, it is contended that the dual pleading requirements of Rule 8 of the Federal Rules of Civil Procedure should align for both jurisdiction and claims. For cases removed to federal court based on diversity, the Supreme Court ruled that defendants must plausibly allege the amount in controversy. Therefore, plaintiffs should similarly be required to provide sufficient facts for a plausible inference regarding the jurisdictional amount. This application of the plausibility standard does not conflict with the precedent allowing jurisdictional discovery for questionable allegations.
The discovery option is available regardless of whether a complaint's allegations initially appear plausible. Without a court's ability to require facially plausible allegations of subject matter jurisdiction, plaintiffs could assert unfounded claims, leading to unnecessary and costly discovery, contrary to the intent of the federal rules for efficient case resolution. Federal courts have a duty to independently determine subject matter jurisdiction, as established in Arbaugh v. Y. H Corp., even without a challenge from parties. It is unreasonable to expect courts to accept baseless claims of jurisdiction without allowing for discovery, which contradicts the principle that cases can be dismissed for lack of jurisdiction when claims are insubstantial or frivolous, as highlighted in Bell v. Hood.
Plaintiffs with legitimate claims should be able to allege plausible facts supporting federal jurisdiction, particularly regarding the amount in controversy. In this case, the complaint fails to plausibly assert an amount in controversy exceeding $75,000. The plaintiff's claim is based on a supposed loss of a job opportunity with the North Korean government valued at $100,000, but he does not provide sufficient facts to support this claim. Furthermore, the plaintiff needed to provide evidence to substantiate his jurisdictional claims as per the court's order, which he has not successfully done. While he provided some evidence for travel and computer expenses, these do not meet the $75,000 threshold, and he failed to substantiate the claimed lost employment opportunity in North Korea.
When jurisdictional facts are contested, the burden lies with the party asserting jurisdiction to provide competent proof and to substantiate its claims by a preponderance of the evidence, as demonstrated in relevant case law. Even if the plaintiff acts in 'good faith,' a complaint may be dismissed if it is clear, to a legal certainty, that the plaintiff cannot recover the necessary jurisdictional amount. In this case, the absence of sufficient evidence leads to the conclusion that federal jurisdiction is lacking. Consequently, the action is dismissed for lack of federal jurisdiction under Fed. R. Civ. P. 12(h)(3). This decision pertains solely to jurisdiction and does not imply that the plaintiff was not subjected to the alleged mistreatment. The ruling allows the plaintiff the option to file a complaint in state court, avoiding the federal amount-in-controversy requirement. The plaintiff's motion for an extension of time is deemed moot, and the Clerk is instructed to close the case. Additionally, the plaintiff's damages claim related to pain, suffering, and emotional distress does not satisfy the jurisdictional threshold, particularly concerning loss of employment in North Korea, and any mistreatment claims are not actionable as the alleged perpetrators are not defendants in this case.
