Seaworth v. State Farm Mutual Automobile Insurance Company
Ronald T. Seaworth v. State Farm Mutual Automobile Insurance Company; Thomas Juarez; James Applewhite; Ted Mikail
- Nancy Brasel
- 0:25-cv-01463
- U.S. District Court · District of Minnesota
- 11
In Seaworth v. State Farm, Judge Tunheim dismissed pro se plaintiff Ronald Seaworth's car insurance dispute without prejudice because the court lacked jurisdiction over the case.
Individuals who file insurance disputes in federal court — particularly pro se plaintiffs in Minnesota — where the core monetary damages are modest. The ruling illustrates that spectacular punitive or treble damage requests will not count toward the $75,000 federal jurisdictional minimum unless supported by specific legal authority and adequate pleading. It also signals that Minnesota's Unfair Claims Practices Act cannot be used as a private remedy in either state or federal court.
What happened
In Seaworth v. State Farm Mutual Automobile Insurance Company, Ronald T. Seaworth, a Minnesota man representing himself, sued State Farm and three of its employees after a dispute over whether his 2022 Honda Sport — damaged when he hit a deer — should be repaired or declared a total loss. Seaworth sought a wide range of damages including repair costs, daily storage fees, treble damages, $300,000 each from three individual employees, and $7.5 million in punitive damages from State Farm.
To bring a lawsuit in federal court based on diversity of citizenship (where the parties are from different states), the amount of money actually at stake must exceed $75,000. The court examined each category of damages Seaworth claimed and found that most of them could not legally be awarded: treble damages lacked any statutory basis he identified; his bad faith claim was procedurally improper as pleaded; the Minnesota unfair claims practices law he cited does not allow private lawsuits; his conspiracy claim was not adequately described; and his punitive damages request lacked any legal or factual support. That left only his core compensatory damages — roughly $27,000 at the time he filed — well below the $75,000 threshold.
Judge Tunheim granted Defendants' motion for judgment on the pleadings in part, dismissing the case without prejudice — meaning Seaworth is not permanently barred from refiling, but would need to correct the problems identified in this ruling. The court denied the part of Defendants' motion seeking dismissal with prejudice, and separately denied as moot Seaworth's own motion for sanctions.
The detailed version
- Seaworth v. State Farm Mutual Automobile Insurance Company · No. 0:25-cv-01463
- Nancy Brasel
- Mar. 11, 2026
Background
Plaintiff Ronald T. Seaworth, proceeding without a lawyer (pro se), filed suit in the United States District Court for the District of Minnesota on April 15, 2025, after a dispute with his automobile insurer, State Farm Mutual Automobile Insurance Company, and three of its employees — Thomas Juarez, James Applewhite, and Ted Mikail. The underlying dispute arose when Seaworth struck a deer on March 11, 2025, with his 2022 Honda Sport. He obtained a repair estimate of $24,292.62 and gathered dealership quotes suggesting a replacement cost of approximately $35,000. State Farm's claims specialists, Juarez and Mikail (who report to Applewhite), determined the vehicle was a total loss under Minnesota's 80% threshold rule. Seaworth disputed that determination.
Seaworth's complaint sought: (1) compensatory damages of $24,292.62 for repairs; (2) $100 per day for vehicle storage from March 17, 2025, to the end of the case; (3) $500 per month for lack of use of his vehicle; (4) treble damages of approximately $83,377.43; (5) $300,000 each from Juarez, Mikail, and Applewhite for bad faith, unlawful settlement practices, and conspiracy; and (6) $7,500,000 in punitive damages from State Farm. He alleged violations of Minnesota state law, citing Minn. Stat. § 168A.01, subd. 17b, and § 72A.201.
Defendants — represented by counsel — moved for Judgment on the Pleadings under Federal Rule of Civil Procedure 12(c), seeking dismissal with prejudice.
Legal Standard
Federal courts have limited jurisdiction. For a federal court to hear a case based on "diversity of citizenship" (parties from different states), 28 U.S.C. § 1332(a) requires that the amount in controversy exceed $75,000, exclusive of interest and costs. The amount in controversy is assessed at the time the complaint is filed. If a defendant challenges the alleged amount, the plaintiff must establish it by a preponderance of the evidence (more likely than not). If it appears to a legal certainty that the claim is for less than $75,000, the case must be dismissed. Under Federal Rule of Civil Procedure 12(h)(3), a court must dismiss any action over which it lacks subject matter jurisdiction.
Analysis
Compensatory Damages
The court calculated Seaworth's compensatory damages as of the filing date (April 15, 2025): $24,292.62 in repair costs plus 29 days of $100/day storage fees ($2,900), totaling approximately $27,192.62 — well below $75,000. The court noted that damages accruing after the filing date do not count toward the jurisdictional amount.
Seaworth argued the damages should be tripled ("trebled") to approximately $83,377.43, which would exceed $75,000. However, the court found Seaworth identified no statutory authority permitting treble damages in this type of case, and Defendants challenged his allegations. Because a plaintiff bears the burden of establishing jurisdiction by a preponderance of the evidence when the defendant challenges it, and Seaworth provided no legal basis for trebling, the court excluded treble damages from the calculation.
Bad Faith Damages
The court analyzed Seaworth's bad faith claim under Minnesota's Insurance Standard of Conduct, Minn. Stat. § 604.18, the most applicable statute even though Seaworth did not cite it by name. The court identified two independent reasons not to include these damages.
First, § 604.18, subdivision 4, expressly prohibits including a bad faith insurance claim in the original complaint. A party must first file suit and then seek to amend the pleadings through a specific motion supported by affidavits. Because Seaworth included the bad faith claim in his original complaint without this procedural step, the court was reluctant to count those damages.
Second, under § 604.18, subd. 3(a), the maximum recoverable amount is one-half of the proceeds awarded in excess of a pre-trial settlement offer made at least ten days before trial, capped at $250,000. Because there was no visibility into the settlement offer amount or trial outcome, the court could not reliably calculate this figure for jurisdictional purposes, and declined to include it.
Unlawful Settlement Practices
Seaworth cited Minn. Stat. § 72A.201, part of Minnesota's Unfair Claims Practices Act. The court rejected this basis entirely, noting that the Minnesota Supreme Court has held that this statute does not provide a private right of action — meaning a private individual cannot sue for money under it. Accordingly, no damages could be recovered on this ground.
Conspiracy
To the extent Seaworth alleged a civil conspiracy among Juarez, Mikail, and Applewhite, the court found the claim inadequately pleaded under the standard of Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007). Seaworth did not allege even the basic elements of a conspiracy claim, let alone supporting facts. Because an improperly pleaded claim cannot support damages for jurisdictional purposes, these amounts were excluded.
Punitive Damages
Punitive damages can in principle count toward the amount in controversy, but only when supported by competent proof and when not barred by law. The court found two independent problems. First, to the extent Seaworth's claims sound in bad faith under § 604.18, that statute expressly prohibits also recovering punitive damages. Second, Seaworth's complaint provided no factual or legal basis supporting the $7.5 million punitive damages request. The court declined to include punitive damages in the amount-in-controversy calculation.
Disposition
With only compensatory damages properly before the court — approximately $27,192.62 — the amount in controversy fell well short of the $75,000 statutory threshold. The court found it lacked subject matter jurisdiction and dismissed the case without prejudice. The court granted Defendants' Rule 12(c) motion in part (dismissal without prejudice) and denied it in part (declining to dismiss with prejudice as Defendants requested). The court expressly declined to address the other arguments Defendants raised or to opine on whether the case could be refiled in state court. Seaworth's pending motion for sanctions (Docket No. 63) was denied as moot.
A footnote in the opinion explains that a dismissal without prejudice means Seaworth may refile, but any new complaint must correct the deficiencies identified in this order.
Read the full 11-page opinion on CourtListener, the free public archive maintained by the Free Law Project.