Also known as: amount in controversy requirement · amount in controversy · jurisdictional amount
Written by attorneys — see sources below.
A statutory monetary threshold that a claim must exceed to support federal diversity jurisdiction under 28 U.S.C. § 1332. The current threshold stands at $75,000 exclusive of interest and costs. A plaintiff satisfies the requirement by alleging the amount in good faith unless it appears to a legal certainty that the claim cannot reach the threshold.
Angela Acosta sues Arcadia Retail in federal court for breach of a supply contract seeking $120,000 in damages. During discovery Arcadia moves for a protective order limiting requests for five years of global sales data. The court denies the motion in part because the amount in controversy justifies targeted production but refuses the full request as disproportionate to the needs of the case.
Adrian Aguilar from State A sues Azure Solutions from State B for $90,000 on a contract claim that meets the amount requirement. Adrian then joins an additional state-law claim for $40,000 arising from the same transaction. The court exercises supplemental jurisdiction over the smaller claim because it shares a common nucleus of operative fact with the anchor claim.
Austin Abbott serves broad interrogatories on Atlas Ventures in a $95,000 diversity suit. Atlas objects that the requests are unduly burdensome given the amount in controversy. The court sustains the objection in part after finding that the discovery requests fail the certification standard that balances burden against the stakes of the case.
Anika Anand files a diversity class action against Argonaut Shipping seeking $80,000 on her individual claim while class members seek smaller sums. The court retains jurisdiction over the class because Anika's claim satisfies the amount-in-controversy requirement and supplemental jurisdiction covers the remaining claims.
Anthony Arnold sues American Express in federal court alleging $85,000 in damages under a contract containing an arbitration clause. The defendant moves to compel arbitration. The court first confirms that the pleaded amount satisfies the diversity threshold before addressing the enforceability of the clause.
Respondents Italian Colors Restaurant and other merchants who accept American Express cards entered into agreements with petitioners American Express and its subsidiary. These agreements required that all disputes be resolved by arbitration and provided that there shall be no right or authority for any claims to be arbitrated on a class action basis. The agreements also included a jury trial waiver and specified that New York law would govern. Respondents filed a class action complaint in the United States District Court for the Southern District of New York. They alleged that American Express violated section 1 of the Sherman Act by using monopoly power in charge cards to force acceptance of credit cards at rates about 30 percent higher than competitors, seeking treble damages under section 4 of the Clayton Act for the class. Petitioners moved to compel individual arbitration under the Federal Arbitration Act. The district court granted the motion and dismissed the lawsuits. On appeal, the Court of Appeals for the Second Circuit reversed, holding the class-action waiver unenforceable because respondents had shown through an economist's declaration that expert analysis costs would be at least several hundred thousand dollars while individual recovery would be at most $38,549 after trebling. The Supreme Court granted certiorari, vacated the judgment, and remanded for consideration in light of Stolt-Nielsen S.A. v. AnimalFeeds International Corp. The Second Circuit stood by its reversal, then reconsidered sua sponte in light of AT&T Mobility LLC v. Concepcion but again reversed. It denied rehearing en banc, after which the Supreme Court granted certiorari to address whether the FAA permits invalidation of arbitration agreements that do not permit class arbitration of federal claims.
View caseAaron Adams files a diversity action in federal court seeking $78,000. The defendant argues that a state procedural rule requiring a higher showing should apply. The court rejects the argument and holds that the federal amount-in-controversy requirement governs the existence of subject-matter jurisdiction.
Shady Grove Orthopedic Associates, P.A., provided medical care to Sonia E. Galvez for injuries she suffered in an automobile accident. As partial payment for that care, Galvez assigned to Shady Grove her rights to insurance benefits under a policy issued in New York by Allstate Insurance Co. Shady Grove tendered a claim for the assigned benefits to Allstate, which under New York law had 30 days to pay the claim or deny it. Allstate apparently paid, but not on time, and it refused to pay the statutory interest that accrued on the overdue benefits at two percent per month. Shady Grove filed this diversity suit in the Eastern District of New York to recover the unpaid statutory interest. Alleging that Allstate routinely refuses to pay interest on overdue benefits, Shady Grove sought relief on behalf of itself and a class of all others to whom Allstate owes interest. The individual claim was worth roughly $500, which fell far short of the amount-in-controversy requirement for individual suits under 28 U.S.C. § 1332(a). The District Court dismissed the suit for lack of jurisdiction. It reasoned that N.Y. Civ. Prac. Law Ann. § 901(b), which precludes a suit to recover a penalty from proceeding as a class action, applies in diversity suits in federal court despite Federal Rule of Civil Procedure 23. Concluding that statutory interest is a penalty under New York law, it held that § 901(b) prohibited the proposed class action.
View caseThe threshold is $75,000 exclusive of interest and costs. A plaintiff satisfies it by alleging the amount in good faith unless it is legally certain the claim cannot reach that figure.
Separate and distinct claims by different plaintiffs cannot be aggregated. Each plaintiff must independently satisfy the threshold unless supplemental jurisdiction applies under the rules established in Exxon Mobil.
The amount in controversy is one factor courts weigh when deciding whether requested discovery is proportional to the needs of the case under Rule 26(b)(1). Larger amounts generally support broader discovery while smaller amounts may justify limits.
No. Jurisdiction is determined at the time of filing. A later recovery below the threshold does not divest the court of subject-matter jurisdiction but may affect the award of costs.
…"[a]ny individual, after any final decision of the Secretary made after a hearing to which he was a party, irrespective of the amount in controversy, may obtain a review of such decision by a civil action commenced within sixty days after the mailing to him of notice of such decision or within such further time as the Secretary may…