Avitts v. Amoco Production
53 F.3d 690 (1995)
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Rule of Law:
For a federal court to exercise federal question subject matter jurisdiction over a case removed from state court, a cause of action arising under federal law must be affirmatively stated on the face of the plaintiff's well-pleaded complaint; a single, vague reference to "Federal law" is insufficient to confer jurisdiction.
Facts:
- W.H. Avitts and other plaintiffs owned property in or near the West Hastings Field in Texas.
- Amoco Production Co. and other defendant companies conducted oil and gas operations in the West Hastings Field.
- The plaintiffs alleged that the defendants' oil and gas operations caused injuries to their property.
- The plaintiffs sought to recover monetary damages from the defendants for the alleged property damage.
Procedural Posture:
- W.H. Avitts and other plaintiffs filed suit against Amoco Production Co. in Texas state district court.
- Amoco removed the action to the United States District Court for the Southern District of Texas, asserting federal question jurisdiction based on a phrase in the plaintiffs' complaint.
- Plaintiffs filed a first amended complaint in federal court which omitted all reference to federal law.
- The district court entered a preliminary injunction requiring Amoco to complete an environmental study.
- The district court subsequently ordered Amoco to pay approximately $650,000 in interim costs and attorney's fees.
- Amoco Production Co. (Defendant-Appellant) appealed these interim orders to the United States Court of Appeals for the Fifth Circuit.
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Issue:
Does a federal district court have subject matter jurisdiction over a case removed from state court where the plaintiff's complaint only makes a single, vague reference to a violation of "Federal law" without pleading a specific federal cause of action?
Opinions:
Majority - Per Curiam
No. A federal district court does not have subject matter jurisdiction because federal question jurisdiction must be determined from the face of the plaintiff's complaint, which did not state a cause of action arising under federal law. Under the well-pleaded complaint rule, the plaintiff is the master of the complaint and may choose to pursue only state-law remedies, even if a federal remedy is available. The original complaint's single, 'nebulous' reference to violations of 'Federal law' was insufficient to establish federal question jurisdiction, and no federal cause of action was ever asserted in any amended complaint. Furthermore, jurisdiction cannot be created after the fact by a simple reference to federal statutes like CERCLA or OPA in a pretrial order as a method for calculating damages; a cause of action must be pleaded. Because the court never had original jurisdiction over a federal claim, there was no basis for supplemental jurisdiction over the state-law claims.
Analysis:
This case serves as a strong reaffirmation of the 'well-pleaded complaint' rule and clarifies its application in the context of removal jurisdiction. It establishes that a defendant cannot seize upon a vague or passing reference to federal law to remove a case that is substantively grounded in state law. The decision underscores the principle that subject matter jurisdiction is a fundamental prerequisite that cannot be waived or created by implication. This precedent limits defendants' ability to forum-shop and ensures that plaintiffs remain the masters of their claims, able to pursue state-law remedies in state court without inadvertently creating federal jurisdiction.
