Reinicke v. Atkins
- Lorna Schofield
- 1:20-cv-01266
- U.S. District Court · Southern District of New York
- 2
In Reinicke v. Atkins, Judge Schofield summarily remanded the case because defendants did not establish the required amount for federal diversity jurisdiction.
The ruling returned Sean MacGuire Reinicke's case against Russell Castello Atkins and the other defendants to state court, ending the federal court's involvement.
What happened
In Reinicke v. Atkins, the defendants removed the case from state court to federal court, asserting that the amount in dispute exceeded $75,000.
The court found that the removal notice showed the amount exceeded $25,000 but did not provide enough facts to show it exceeded the $75,000 threshold required for federal diversity jurisdiction.
Judge Lorna G. Schofield summarily remanded the matter to state court and directed the clerk to close the federal case.
The detailed version
- Reinicke v. Atkins · No. 1:20-cv-01266
- Lorna Schofield
- Feb. 14, 2020
Background
Defendants Russell Castello Atkins and the other defendants filed a notice removing the case from state court to the U.S. District Court for the Southern District of New York. The notice stated that the complaint sought more than $75,000, but it did not allege additional facts supporting that amount.
Jurisdictional Analysis
Federal diversity jurisdiction under 28 U.S.C. § 1332(a) requires the amount in controversy to exceed $75,000, exclusive of interest and costs. The party seeking to establish diversity jurisdiction bears the burden of showing that the requirement is met. The court concluded that the notice established an amount exceeding $25,000, but defendants had not established that the amount exceeded $75,000. Because doubts about removal must be resolved against removal, the court found that federal jurisdiction was not established.
Ruling
The court ordered that the matter be summarily remanded to the Supreme Court of the State of New York, New York County. It directed the clerk to mail a certified copy of the order to that court and to close the federal case. Judge Lorna G. Schofield signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.