Farmilant v. Singapore Airlines, Ltd.
1983 U.S. Dist. LEXIS 17671, 561 F. Supp 1148 (1983)
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Rule of Law:
A federal court must dismiss a case for lack of subject matter jurisdiction if, at the summary judgment stage, the uncontroverted facts establish to a legal certainty that the plaintiff cannot recover damages in excess of the statutory amount-in-controversy requirement.
Facts:
- On November 12, 1981, Eugene Farmilant purchased a multi-leg airline ticket from Singapore Airlines in Chicago for a trip through Asia, requesting that all segments after the first flight be left 'open' without specific reservations.
- After beginning his trip, Farmilant altered his itinerary, first adding a stop in Hong Kong.
- In Hong Kong, Farmilant booked a flight to Singapore but was only placed on a waitlist for the connecting flight to his ultimate destination, Madras, India.
- Upon arriving in Singapore on December 13, Farmilant was informed there were no available seats to Madras for three weeks; the airline instead arranged for him to fly to Bombay on December 16.
- Farmilant took a train from Bombay to Madras, during which he became ill after eating food from a vendor.
- Due to his illness, Farmilant decided to end his trip and return to the United States.
- Farmilant attempted to book a return flight on Singapore Airlines from Madras but was told the earliest availability was over a month away, prompting him to purchase a ticket home on a different airline.
Procedural Posture:
- Eugene Farmilant filed a lawsuit against Singapore Airlines, Ltd. in the U.S. District Court for the Northern District of Illinois, asserting diversity jurisdiction.
- Farmilant's complaint included claims for fraudulent misrepresentation, tortious breach of contract, negligence, and willful and wanton conduct.
- Singapore Airlines filed a motion for summary judgment.
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Issue:
Does a federal court have subject matter jurisdiction over a diversity case when the uncontroverted facts establish to a legal certainty that the plaintiff cannot recover damages exceeding the statutory jurisdictional amount?
Opinions:
Majority - Shadur, District Judge
No. A federal court lacks subject matter jurisdiction over a diversity case when the uncontroverted facts establish to a legal certainty that the plaintiff cannot recover damages exceeding the statutory jurisdictional amount. The court reasoned that Farmilant's claimed damages could not legally meet the $10,000 threshold. The damages from his illness were not recoverable from the Airline because the illness was caused by an intervening, unforeseeable event—eating tainted food on a train trip operated by another party. The remaining compensatory damages for travel and lodging were clearly far less than $10,000. Furthermore, punitive damages were unavailable because Farmilant failed to present any facts supporting an inference of malice, fraud, or willful misconduct; at most, the Airline's actions constituted mere negligence, which is insufficient to support a claim for punitive damages.
Analysis:
This opinion illustrates the court's role as a gatekeeper for its own subject matter jurisdiction, particularly concerning the amount-in-controversy requirement. It demonstrates that while a plaintiff's initial allegations of damages are often taken at face value, a court can scrutinize the legal basis for those damages at the summary judgment stage. The case establishes that if the undisputed facts show it is a 'legal certainty' that the plaintiff cannot recover the jurisdictional minimum, the court must dismiss the case. This reinforces the principle that federal jurisdiction cannot be manufactured by pleading legally unrecoverable damages, such as punitive damages without evidence of malice or damages caused by a clear intervening act.
