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S.D.N.Y.Procedural orderFiled Aug. 11, 2022

Brown v. Miller Auto Leasing

Judge
Lewis Liman
Docket
1:22-cv-02431
Court
U.S. District Court · Southern District of New York
Pages
1
Civil Procedure
In one sentence

In Brown v. Miller Auto Leasing, Judge Liman found a reasonable probability that damages exceeded $75,000, supporting diversity jurisdiction.

Who this affects

Shanna Brown, Miller Auto Leasing, and Ajaqua Hawkins; the order concerns whether the federal court’s diversity-jurisdiction amount requirement was met.

What happened

Brown v. Miller Auto Leasing involved the defendants’ removal of the case to federal court. At an initial conference, the court questioned the defendants’ statement that the amount in dispute would exceed $75,000.

Plaintiff’s counsel said Shanna Brown sought more than $75,000 for injuries to her neck, back, knees, and hip, possible surgery, and lost work after the accident. The court concluded there was a reasonable probability that the amount-in-controversy requirement for diversity jurisdiction was met.

Judge Lewis J. Liman issued the order on August 11, 2022. The order addressed only the jurisdictional amount and did not decide the underlying claims or damages.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Brown v. Miller Auto Leasing · No. 1:22-cv-02431
Judge
Lewis Liman
Date
Aug. 11, 2022

Background

The court held an initial pretrial conference on August 10, 2022. The defendants’ notice of removal stated that, based on information and belief, the plaintiff’s alleged amount in controversy would exceed $75,000. The court asked about the basis for that assertion.

Representations About Damages

Plaintiff’s counsel represented that Shanna Brown was seeking more than $75,000 in damages. Counsel said Brown had suffered injuries to various body parts, including her neck, back, knees, and hip; might need surgery if physical therapy did not resolve the injuries; and had been unable to work because of the accident.

Ruling

The court stated that it was satisfied there was a “reasonable probability” that the plaintiff’s damages claim met the amount-in-controversy requirement for diversity jurisdiction. The order did not decide liability, the amount of damages, or the merits of the underlying claims. Judge Lewis J. Liman ordered the ruling on August 11, 2022.

The authoritative version

Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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