Brinson v. Quincy Amusements, Inc.
- James Oetken
- 1:19-cv-05026
- U.S. District Court · Southern District of New York
- 2
In Brinson v. Quincy Amusements, Judge Oetken granted remand because the amount in controversy was $75,000 or less.
The parties to the case are affected because the federal court granted remand and returned the case to New York Supreme Court, Bronx County.
What happened
Brinson v. Quincy Amusements, Inc. was removed from New York Supreme Court, Bronx County, to federal court. The parties then filed a motion asking the federal court to send the case back to state court and agreed that the amount at issue did not exceed $75,000.
The court explained that federal courts may hear cases between citizens of different states only when more than $75,000 is at stake, excluding interest and costs. Because the amount in controversy did not exceed that threshold, the court concluded that it lacked authority to hear the case.
Judge J. Paul Oetken granted the motion to remand and sent the case back to New York Supreme Court, Bronx County, under 28 U.S.C. § 1447(c).
The detailed version
- Brinson v. Quincy Amusements, Inc. · No. 1:19-cv-05026
- James Oetken
- Nov. 21, 2019
Background
The case was removed from New York Supreme Court, Bronx County, on May 30, 2019. On November 20, 2019, the parties filed a motion seeking remand to state court, together with a stipulation that the amount in controversy did not exceed $75,000.
Jurisdiction
Federal courts have limited jurisdiction, meaning they may hear only matters authorized by the Constitution and federal statutes. Under the diversity-jurisdiction statute, 28 U.S.C. § 1332(a)(1), federal courts may hear cases between citizens of different states when the amount in controversy exceeds $75,000, excluding interest and costs. Under 28 U.S.C. § 1447(c), a federal court must remand a removed case if it appears before final judgment that the court lacks subject-matter jurisdiction, meaning authority over the type of dispute.
The court concluded that the amount in controversy did not exceed $75,000 and therefore that it lacked subject-matter jurisdiction.
Ruling
Judge J. Paul Oetken granted the motion to remand. The case was remanded to New York Supreme Court, Bronx County, under 28 U.S.C. § 1447(c).
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.