Lewis v. State Farm
- Philip Halpern
- 7:23-cv-08089
- U.S. District Court · Southern District of New York
- 3
In Lewis v. State Farm, Judge Halpern dismissed the action because Lewis and Owens were both New York citizens and no federal-law claim supplied jurisdiction.
Regina Lewis, State Farm, and John W. Owens were affected. The action was dismissed for lack of subject-matter jurisdiction, the pending pre-motion conference requests were denied as moot, and the case was closed.
What happened
Regina Lewis sued State Farm and John W. Owens over state-law products-liability and negligence claims. The court had previously given Lewis a chance to remove Owens because his citizenship defeated diversity jurisdiction, but she kept him as a defendant.
The court found that Lewis and Owens were both New York citizens, so complete diversity was missing. It also found no federal-law claim in the amended complaint. The court dismissed the action for lack of subject-matter jurisdiction and denied the pending requests for a pre-motion conference as moot.
Judge Philip M. Halpern issued the order on August 21, 2024. He directed the Clerk of Court to terminate the pending letter-motions, close the case, and mail the order to Lewis.
The detailed version
- Lewis v. State Farm · No. 7:23-cv-08089
- Philip Halpern
- Aug. 21, 2024
Background
Regina Lewis brought state-law products-liability and negligence claims against State Farm and John W. Owens. The court previously gave Lewis an opportunity to drop Owens because his presence defeated diversity of citizenship. Lewis instead filed an amended complaint that continued to assert claims against Owens and alleged jurisdiction under 28 U.S.C. § 1332(a)(2), based on the amount in controversy exceeding $75,000.
Jurisdiction
The court examined whether it had subject-matter jurisdiction, meaning legal authority to hear the case. It determined that Lewis and Owens were both citizens of New York, so complete diversity was lacking. The court also reviewed the amended complaint for a federal question and found no facts showing a claim under federal law; the allegations described only state-law products-liability and negligence claims.
Rulings
Under Federal Rule of Civil Procedure 12(h)(3), the court dismissed the action for lack of subject-matter jurisdiction. The court also denied as moot the letter-motions seeking a pre-motion conference concerning anticipated motions to dismiss for lack of subject-matter jurisdiction. The Clerk of Court was directed to terminate those letter-motions, close the case, and mail a copy of the order to Lewis.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.