Reid v. Blair

Background

The caption identifies Molly M. Reid as the plaintiff. She brought a New York state-law negligence action against Anthony D. Blair and Blackwater Enterprises, Inc., alleging that negligent operation of a motor vehicle caused her personal injuries. The complaint sought damages in an amount exceeding the limits of lower New York courts and satisfying the requirements for federal diversity jurisdiction.

The defendants removed the case from the Supreme Court of the State of New York, Bronx County, to the United States District Court for the Southern District of New York under the federal diversity-jurisdiction and removal statutes. They asserted that the parties were completely diverse— the opinion states that the plaintiff was a New York citizen and the defendants were Georgia citizens—and that the amount in controversy exceeded $75,000. They removed the case on October 29, 2021, within 30 days of the plaintiff’s response to a demand stating that she sought $2,000,000.

The plaintiff moved to remand, meaning to return the case to state court, arguing that the defendants missed the federal removal deadline. Magistrate Judge Stewart D. Aaron recommended granting the motion. He concluded that the complaint itself allowed the defendants to determine that the case was removable, so the 30-day deadline began when Blackwater was served on March 1, 2021.

Analysis

Judge Hellerstein reviewed the defendants’ objections to the recommendation. He agreed that the complaint’s damages-demand clause clearly stated that the plaintiff sought an amount satisfying diversity jurisdiction. The clause’s reference to 28 U.S.C. § 1331 rather than § 1332 did not change the result. The court reasoned that the only possible federal basis identified in this case was diversity jurisdiction because the complaint asserted only a state-law claim, and the defendants could have sought clarification if they were confused.

The court also rejected the defendants’ reading of Moltner v. Starbucks Coffee Co. The court explained that Moltner requires a paper served on the defendant to explicitly disclose that the amount sought meets the federal jurisdictional threshold, but it does not require a specific dollar figure. The complaint’s statement that the damages satisfied diversity jurisdiction was enough. The plaintiff’s later response stating the $2,000,000 amount was therefore not necessary to start the removal period.

The court distinguished the defendants’ reliance on Remy and Oakes. Those cases involved complaints that did not provide enough information to establish that the amount-in-controversy requirement was met. This case instead presented a timing problem: the complaint had already made removability clear, so the defendants had to remove within 30 days after Blackwater’s service.

Ruling

Judge Hellerstein adopted Magistrate Judge Aaron’s report and recommendation and granted the plaintiff’s motion to remand. The court ordered the Clerk to remand the action to the Supreme Court of the State of New York, Bronx County, terminate the motion, and close the federal case. The opinion did not decide the underlying negligence or personal-injury claims.

Name discrepancy

The opinion’s caption identifies the plaintiff as “MOLLY M. REID,” while the body repeatedly refers to her as “Molly M. Blair.” This summary follows the caption and does not resolve that discrepancy.