Carlin v. United Healthcare Insurance Company of New York
Patricia L. Carlin et al. v. United Healthcare Insurance Company of New York, Inc. et al.
- Jesse Furman
- 1:24-cv-08435
- U.S. District Court · Southern District of New York
- 4
In Carlin v. United Healthcare, Judge Furman kept the case in federal court because punitive damages might raise the claims above $75,000.
Patricia L. Carlin and the other plaintiffs may continue pursuing the case in federal court at this stage; the defendants must respond to the Third Amended Complaint and participate in the scheduled pretrial process.
What happened
Patricia L. Carlin and other plaintiffs sued United Healthcare Insurance Company of New York, Inc. and other defendants. In response to the court’s order, the plaintiffs argued that the parties were citizens of different states and that the amount at issue could exceed $75,000. Their individual unpaid medical claims were below $75,000, but they also sought punitive damages.
The court explained that separate plaintiffs generally cannot combine their claims to reach the required amount. However, potentially recoverable punitive damages may count. Although the court was skeptical that the plaintiffs would ultimately recover punitive damages, it concluded that their allegations of intentional and malicious misconduct and breach of fiduciary duty did not make recovery legally impossible.
Judge Furman ruled that dismissal at this stage was not appropriate and concluded that the amount-in-controversy requirement was met for federal diversity jurisdiction. The defendants must answer or otherwise respond to the Third Amended Complaint by December 10, 2025, and the court scheduled an initial pretrial conference for December 17, 2025.
The detailed version
- Carlin v. United Healthcare Insurance Company of New York · No. 1:24-cv-08435
- Jesse Furman
- Nov. 20, 2025
Background
The plaintiffs responded to the court’s order directing them to explain why the case should not be dismissed for lack of diversity jurisdiction. They argued that the parties were completely diverse and that the amount in controversy plausibly exceeded $75,000. The court reviewed that response and the Third Amended Complaint.
Diversity jurisdiction is a federal court’s authority to hear certain disputes between citizens of different states when the amount in controversy exceeds $75,000. For declaratory relief, courts measure the amount by the value of what the lawsuit seeks to obtain. Dismissal is appropriate on this ground only when it is legally certain that the claim is worth less than the required amount.
Amount in Controversy
The plaintiffs acknowledged that each plaintiff’s individual unpaid medical claims totaled less than $75,000. The court explained that, unlike in some class actions under the Class Action Fairness Act, separate plaintiffs generally may not combine their individual claims to satisfy the jurisdictional amount. Combining claims is allowed only when the plaintiffs seek to enforce a single right or title in which they share a common and undivided interest.
The plaintiffs also sought punitive damages. Potentially recoverable punitive damages may be included in calculating the amount in controversy when the governing law permits them. The court noted that punitive damages ordinarily are unavailable for fraud or contract claims under New York law, but may be available in narrow circumstances, including conduct involving recklessness or willfulness. The plaintiffs alleged that the defendants’ misconduct was intentional, malicious, fraudulent, despicable, and oppressive, and they alleged breach of fiduciary duty.
Although the court expressed skepticism that the plaintiffs would ultimately recover punitive damages, it concluded that the record did not make recovery legally impossible. The court therefore concluded that the amount in controversy exceeded $75,000 for purposes of diversity jurisdiction.
Ruling and Next Steps
The court concluded that dismissal at this stage would not be appropriate. It directed the defendants to answer or otherwise respond to the Third Amended Complaint by December 10, 2025. It also scheduled the initial pretrial conference for December 17, 2025, to be held remotely by telephone, and reminded the parties to file the required joint letter before that conference.
Judge Jesse M. Furman issued the memorandum opinion and order on November 20, 2025.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.