斯廷森诉纳瓦案

On August 19, 2022, plaintiff Tracy Stinson was a passenger in a vehicle that collided with a vehicle driven by defendant Brinlee Nava in Alabama. Stinson filed a negligence and wantonness complaint in the Circuit Court of Jefferson County on May 8, 2024, also asserting claims against GEICO and Allmerica for failure to pay uninsured/underinsured motorist benefits. Defendant Nava removed the case to the U.S. District Court for the Northern District of Alabama on June 24, 2024, citing diversity jurisdiction. Stinson moved to remand, arguing the amount in controversy did not exceed the $75,000 threshold. On October 8, 2024, Magistrate Judge Gray M. Borden granted the motion to remand.

Magistrate Judge Gray M. Borden granted Plaintiff Tracy Stinson's Motion to Remand, holding that defendants failed to establish that the amount in controversy exceeded $75,000. The case was remanded to the Circuit Court of Jefferson County, Alabama.

Whether the amount in controversy exceeded $75,000, the jurisdictional threshold for federal diversity jurisdiction under 28 U.S.C. § 1332. The complaint did not specify damages, and Stinson's medical expenses were documented at only $22,107.74. While a demand letter suggested a settlement of $82,107.74, the court found this lacked sufficient justification. Defendants failed to provide evidence of ongoing medical expenses or substantial emotional damages.

The case reaffirms the strict construction of removal statutes and the presumption against federal jurisdiction. It clarifies that defendants bear the burden of proving the amount in controversy, and that settlement demand letters alone—without supporting evidence—are insufficient to establish federal jurisdiction. The decision serves as a reminder that federal courts are courts of limited jurisdiction and that ambiguous cases should be resolved in favor of remand to state court.