Aponte-Davila v. Municipality of Caguas
2016 WL 3648474, 828 F.3d 40 (2016)
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Rule of Law:
For the purpose of diversity jurisdiction, a person does not change their domicile by temporarily residing in another state to receive medical treatment, so long as they lack the intent to make that new location their permanent home and maintain an intent to return to their established domicile.
Facts:
- José Aponte-Dávila, a professional truck driver, established his domicile in Laredo, Texas in 2007, obtaining a Texas commercial driver's license in 2008.
- Aponte-Dávila filed all federal tax returns from 2007 to 2012 using his Texas address and never filed state income tax returns in Puerto Rico.
- On July 13, 2009, while visiting Puerto Rico to get married, Aponte-Dávila was injured in a slip-and-fall accident.
- Between 2009 and 2013, he traveled back and forth between Texas for work and Puerto Rico for medical care, staying with family while in Puerto Rico.
- During his recovery periods in Puerto Rico, Aponte-Dávila obtained a Puerto Rico driver's license, a disability parking permit, and government health benefits, listing a local address on the applications.
- In May 2012, after a paralyzing back pain incident in Laredo, Aponte-Dávila sold his truck and returned to Puerto Rico for an extended recovery period lasting until April 2013.
- In late April 2013, Aponte-Dávila returned to Laredo, Texas, to seek employment as a trucker.
- On May 6, 2013, three days before filing the lawsuit, he obtained a medical certificate in Texas as part of the process to renew his Texas commercial driver's license.
Procedural Posture:
- José Aponte-Dávila filed a negligence complaint against the Municipality of Caguas and others in the U.S. District Court for the District of Puerto Rico, asserting diversity jurisdiction.
- The defendants filed answers challenging the court's subject-matter jurisdiction and subsequently filed a motion to dismiss.
- The district court, ruling on a paper record without an evidentiary hearing, granted the defendants' motion to dismiss.
- The district court found that Aponte-Dávila was domiciled in Puerto Rico when the suit was filed, which defeated complete diversity.
- Aponte-Dávila, the plaintiff, appealed the dismissal to the U.S. Court of Appeals for the First Circuit.
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Issue:
Does a person change their domicile for diversity jurisdiction purposes by residing in a former state to receive extended medical care, when they maintain an intent to return to their established domicile?
Opinions:
Majority - Lynch, Circuit Judge.
No. A person does not change their domicile simply by residing in another state for medical care when they do not intend to make that state their new permanent home. A person's domicile is established by both physical presence and the intent to remain indefinitely. Aponte-Dávila was domiciled in Texas before his accident, and his subsequent stays in Puerto Rico were for the primary purpose of medical treatment and recovery, which is consistent with transient status rather than a permanent relocation. The court placed too much weight on documents listing a Puerto Rico residence, as these were often tied to the necessity of obtaining medical care and do not, by themselves, prove an intent to change domicile. Aponte-Dávila's continued maintenance of his Texas-based career, filing federal taxes from Texas, and taking steps to renew his Texas commercial driver's license immediately upon his return demonstrate a continuous intent to return to Texas, which remained his true, fixed home.
Analysis:
This decision clarifies the domicile analysis for diversity jurisdiction, particularly in cases involving temporary relocation for medical reasons. It reinforces the principle that domicile requires more than mere residence; it requires an intent to remain. The court's focus on the 'substantive nature' of a person's contacts with a state, rather than just the number of contacts, provides a crucial analytical framework. This precedent instructs lower courts to weigh evidence of intent, such as professional licensing and tax filings, heavily against residency documents obtained out of necessity or convenience during a temporary stay for healthcare.
