Roc-Le Triomphe Associates, LLC v. TaskRabbit, Inc.
- Lorna Schofield
- 1:23-cv-07634
- U.S. District Court · Southern District of New York
- 3
In Roc Le Triomphe v. Task Rabbit, Judge Schofield held federal diversity jurisdiction exists because the claimed damages exceed $75,000.
Roc Le Triomphe, LLC and Task Rabbit, Inc.; the case will proceed in federal court under the court’s case-management procedures.
What happened
Roc Le Triomphe, LLC sued Task Rabbit, Inc. in state court, alleging that Task Rabbit’s conduct caused a gas-line penetration and seeking at least $70,000 in damages. Task Rabbit moved the case to federal court, claiming the parties were citizens of different states and that more than $75,000 was at stake.
The court examined an email Roc Le Triomphe sent during settlement discussions stating that its damages totaled $87,836. The court found that the detailed, invoice-based estimate reasonably showed that the amount in dispute exceeded the $75,000 federal threshold, and that Task Rabbit removed the case within the required 30-day period.
Judge Schofield concluded that federal jurisdiction requirements were satisfied and ordered the parties to proceed under a case-management and scheduling order. The order did not decide whether either party was liable for the alleged gas-line damage.
The detailed version
- Roc-Le Triomphe Associates, LLC v. TaskRabbit, Inc. · No. 1:23-cv-07634
- Lorna Schofield
- Nov. 13, 2023
Background
Roc Le Triomphe, LLC filed a negligence action in New York state court concerning the penetration of a gas line. Its pleading sought damages “not less than” $70,000. Task Rabbit, Inc. removed the case to federal court, asserting diversity jurisdiction under 28 U.S.C. § 1332. Diversity jurisdiction allows a federal court to hear a civil case involving citizens of different states when more than $75,000 is in controversy, excluding interest and costs.
The parties did not dispute that they were completely diverse: the opinion states that Roc Le Triomphe is a New York corporation with its principal place of business in New York, while Task Rabbit is a Delaware corporation with its principal place of business in California.
Amount in Controversy
Because the complaint did not clearly establish that more than $75,000 was at stake, the court considered evidence outside the pleadings. Task Rabbit relied on an August 7, 2023, email from Roc Le Triomphe during settlement discussions. The email stated that total damages were $87,836, including $31,736 for repairs and replacements and $56,100 in rent credits for tenants who lacked gas service.
The court held that a settlement offer may help establish the amount in controversy when it reasonably estimates the value of the claim. It found that Roc Le Triomphe’s email gave a detailed estimate supported by numerical information and therefore reasonably reflected the claim’s value. The court also found that Task Rabbit filed its removal notice within 30 days after receiving the email.
Ruling
The court concluded that the requirements for diversity jurisdiction had been satisfied. It ordered the parties to proceed under a case-management plan and scheduling order to be issued separately. The order also addressed procedures that would apply if Task Rabbit later sought to file a motion to dismiss. The court did not decide the underlying negligence claim or determine liability for the gas-line damage.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.