Steele v. Combined Life Insurance Company of New York Chubb
- Louis Stanton
- 1:20-cv-10252
- U.S. District Court · Southern District of New York
- 5
In Steele v. Combined Life Insurance Company of New York Chubb, Judge Stanton dismissed for lack of jurisdiction but allowed amendment.
Beatrice S. Williams Steele’s insurance-contract lawsuit was dismissed for lack of subject-matter jurisdiction, but she was given 30 days to amend. Combined Life Insurance Company of New York Chubb remains the defendant named in the action.
What happened
In Beatrice S. Williams Steele v. Combined Life Insurance Company of New York Chubb, the plaintiff sued her supplemental medical insurance company for allegedly failing to pay for brain surgery and sought $7 million.
The court found that the complaint did not provide enough information to show that the parties were citizens of different states. It also noted that the complaint did not show that the amount in controversy exceeded $75,000.
Judge Louis L. Stanton dismissed the action for lack of subject-matter jurisdiction but granted the plaintiff 30 days to file an amended complaint showing that federal diversity jurisdiction exists. If she does not amend within that time, the court will enter judgment dismissing the action for lack of jurisdiction.
The detailed version
- Steele v. Combined Life Insurance Company of New York Chubb · No. 1:20-cv-10252
- Louis Stanton
- Jan. 22, 2021
Background
Beatrice S. Williams Steele, who was proceeding without a lawyer, sued the “Combined Life Insurance Company of New York Chubb” (CLI) and sought $7 million in damages. The court understood her complaint to allege that CLI, her supplemental medical insurance company, failed to pay a claim for brain surgery scheduled for December 7, 2020. The court treated the claim as a state-law breach-of-contract claim based on an insurance policy.
The court had previously allowed Steele to proceed without paying filing fees. When a person proceeds without paying those fees, the court must screen the complaint and dismiss it if it is frivolous, malicious, fails to state a claim, seeks money from an immune defendant, or does not come within the court’s subject-matter jurisdiction. The court also said it must read a complaint filed without a lawyer liberally and consider the strongest claims the allegations suggest.
Jurisdiction analysis
The court considered diversity jurisdiction, which allows a federal court to hear certain state-law claims when the parties are citizens of different states and more than $75,000 is at stake. Complete diversity is required, meaning no plaintiff and defendant may be citizens of the same state.
The court stated that Steele was a citizen of Bronx County, New York. But she did not allege facts establishing CLI’s state citizenship. Her attached documents identified CLI’s “home office” as being in Latham, New York, but she did not state whether CLI was a corporation, a limited liability company, or another type of entity. The court therefore could not determine CLI’s citizenship and noted that CLI might also be a citizen of New York. The court also stated that Steele had not alleged facts showing that the amount-in-controversy requirement was satisfied.
Ruling
The court dismissed the action for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3). It granted Steele 30 days to file an amended complaint alleging facts that clearly show the court may exercise diversity jurisdiction over her state-law claims. The order did not state that the dismissal was with or without prejudice. If Steele does not file an amended complaint within the allowed period, the court will enter judgment dismissing the action for lack of subject-matter jurisdiction. Judge Louis L. Stanton directed the Clerk of Court to mail the order to Steele and note service on the docket.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.