Coyukiat v. Stryker Corporation
- Philip Halpern
- 7:21-cv-02046
- U.S. District Court · Southern District of New York
- 4
Judge Halpern remanded Coyukiat v. Stryker Corporation because Defendants did not establish that more than $75,000 was in dispute.
The ruling returned Judy Chu Coyukiat’s personal-injury action against Howmedica Osteonics Corp., Stryker Corporation, and Stryker Sales Corporation to New York state court; it did not decide the underlying injury claims.
What happened
In Coyukiat v. Stryker Corporation, Judy Chu Coyukiat sued the Defendants in New York state court, alleging that a screw they designed, manufactured, and distributed caused a hip fracture after it was implanted in her body. The Defendants removed the case to federal court, claiming that the parties were completely diverse and that the damages would exceed $75,000.
The court explained that the party seeking federal diversity jurisdiction must show, based on the evidence, that more than $75,000 was at stake. Because the complaint did not state a specific damages amount and the Defendants offered only a conclusory statement that the damages would exceed $75,000, the court found that the jurisdictional requirement had not been established.
Judge Halpern ruled that removal was improper and remanded the action to the Supreme Court of the State of New York, County of Rockland. The Clerk was directed to send that court a copy of the order and close the federal case; all pending matters were terminated.
The detailed version
- Coyukiat v. Stryker Corporation · No. 7:21-cv-02046
- Philip Halpern
- Mar. 15, 2021
Background
Judy Chu Coyukiat filed a personal-injury complaint in the Supreme Court of the State of New York, County of Rockland. She alleged that a screw designed, manufactured, and distributed by Howmedica Osteonics Corp., Stryker Corporation, and Stryker Sales Corporation caused a fracture in her hip after being implanted in her body. She sought compensatory damages for physical injuries, pain, and suffering, but did not state a specific dollar amount.
The Defendants removed the action to the U.S. District Court for the Southern District of New York under the federal diversity-jurisdiction statutes. They asserted that complete diversity existed and stated, “upon information and belief,” that the damages would exceed $75,000.
Analysis
Federal diversity jurisdiction requires that the amount in controversy exceed $75,000 and that the dispute be between citizens of different states. The party invoking that jurisdiction bears the burden of establishing the required amount. When state law does not allow a personal-injury complaint to demand a specific sum, the federal court must find by a preponderance of the evidence that the amount in controversy exceeds $75,000.
The court concluded that the complaint’s allegations of a hip fracture, physical injury, and pain and suffering did not themselves establish the jurisdictional amount. The Defendants merely repeated those allegations and made a conclusory assertion that the damages would exceed $75,000. The court stated that this was insufficient to establish the amount in controversy. It also noted that New York law allowed the Defendants to request a supplemental demand identifying the damages sought.
Ruling
Judge Philip M. Halpern concluded that, even assuming complete diversity, the Defendants failed to satisfy their burden of establishing that the amount in controversy exceeded $75,000. The court held that removal was improper and remanded the action to the Supreme Court of the State of New York, County of Rockland. The Clerk was directed to send that court a copy of the order and close the federal action. The order also terminated all pending matters.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.