Lujan v. Sensio Company Inc.

Background

Bonnie Lujan alleged that a Bella Electric Pressure Cooker exploded when she tried to open it on or about January 7, 2024. She alleged that hot liquid, food contents, and steam struck her, causing painful and disfiguring burns, pain and suffering, mental anguish, embarrassment, loss of enjoyment of life, disability, and medical expenses. Her claims included strict product liability, negligence, breach of express warranty, breach of the implied warranty of merchantability, breach of the implied warranty of fitness for a particular purpose, and failure to warn.

Lujan alleged federal jurisdiction based on diversity of citizenship and an amount in controversy exceeding $75,000. The Sensio Defendants did not dispute the citizenship requirement but challenged the amount in controversy under Federal Rule of Civil Procedure 12(b)(1), which permits dismissal when the court lacks subject-matter jurisdiction.

Evidence and Arguments

The Sensio Defendants argued that Lujan’s medical bills and lost wages totaled only $2,459.48. Lujan did not dispute that calculation but argued that her noneconomic damages and damages for physical impairment and disfigurement could exceed the jurisdictional threshold.

The evidence showed that Lujan’s burns covered seven percent of her body. Her medical records described mostly first-degree burns and two spots of second-degree burns, with blistering and follow-up wound-care treatment. She stated that she experienced flashbacks, could no longer use pressure cookers, and felt self-conscious about scarring. The opinion states that she did not have a formal diagnosis of post-traumatic stress disorder or treatment for it.

Court’s Analysis

A plaintiff invoking diversity jurisdiction must show a reasonable probability that more than $75,000 is in controversy. The face of the complaint is generally presumed to represent the amount in controversy in good faith. The defendant opposing jurisdiction must show to a legal certainty that the plaintiff cannot recover the required amount.

The court applied Colorado law to the damages issue. Under that law, personal-injury damages may include economic damages, noneconomic damages such as pain and suffering and emotional distress, and separate damages for physical impairment or disfigurement. The court stated that Colorado law does not require medical testimony to establish pain and suffering and does not impose a precise formula or threshold for noneconomic or disfigurement damages.

Although the evidence established only $2,459.48 in economic damages, the court concluded that the evidence did not establish to a legal certainty that Lujan could not recover at least $73,000 in noneconomic damages and damages for physical impairment or disfigurement. The court also rejected the Sensio Defendants’ argument that Lujan could not recover emotional-distress damages because she lacked a formal diagnosis. The court explained that this was a physical-injury case, not a claim for emotional distress standing alone.

Ruling

Judge Lewis J. Liman denied the Sensio Defendants’ motion to dismiss for lack of subject-matter jurisdiction. The Clerk of Court was directed to close the motion on the docket. The opinion did not decide whether Lujan would ultimately prevail on her product-liability or other claims; it decided only that the amount-in-controversy requirement for federal jurisdiction had not been disproved to the required legal certainty.