O'BRIEN v. Jansen
1995 WL 678622, 903 F. Supp. 903, 1995 U.S. Dist. LEXIS 17109 (1995)
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Rule of Law:
The party invoking a federal court's diversity jurisdiction bears the burden of establishing it by a preponderance of the evidence. If the evidence regarding a defendant's domicile is in equipoise, suggesting multiple possible states of citizenship, the plaintiff has failed to meet this burden and the case must be dismissed for lack of jurisdiction.
Facts:
- In September 1993, the defendant, a 17-year-old domiciliary of Pennsylvania, began attending the University of Maryland.
- After the defendant's 18th birthday, his parents moved from Pennsylvania to Illinois.
- The defendant resided with his brother in Baltimore, Maryland during some school breaks, including the summer of 1994.
- In December 1994, a physical confrontation occurred between the defendant and the plaintiff, a Maryland resident, on the university campus.
- At the time the lawsuit was filed in May 1995, the defendant retained his Pennsylvania driver's license and had filed his state tax returns in Pennsylvania for the previous three years.
- The defendant had not registered to vote in any state.
- In response to discovery requests, the defendant identified his parents' Illinois address as his 'permanent address' but his brother's Baltimore address as his 'primary residence'.
Procedural Posture:
- The plaintiff, a resident of Maryland, filed a complaint for battery and intentional infliction of emotional distress against the defendant in the U.S. District Court for the District of Maryland.
- The plaintiff's complaint alleged that the court had diversity jurisdiction because the defendant was a citizen of Illinois.
- In his answer, the defendant denied that he was a citizen of Illinois.
- The district court judge ordered both parties to submit legal memoranda on the issue of jurisdiction.
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Issue:
Does a federal district court have diversity jurisdiction over a case when the plaintiff fails to prove by a preponderance of the evidence that the defendant, a college student with ties to multiple states, is domiciled in a state different from the plaintiff?
Opinions:
Majority - Davis, J.
No. The court lacks diversity jurisdiction because the plaintiff failed to meet their burden of establishing the defendant's diverse citizenship by a preponderance of the evidence. A person's pre-existing domicile is presumed to continue, but that presumption is weakened here because the defendant's parents moved after he reached the age of majority, and he established significant ties to Maryland, including residing there during breaks and describing it as his 'primary residence.' The evidence is in equipoise, making it equally plausible that the defendant is a domiciliary of Pennsylvania, Illinois, or Maryland. Because the plaintiff could not definitively prove the defendant was not a Maryland domiciliary, and there is no presumption in favor of federal jurisdiction, the plaintiff has failed to carry their burden.
Analysis:
This case illustrates the critical principle that federal courts are courts of limited jurisdiction, and the burden of proof rests squarely on the party asserting that jurisdiction exists. It highlights the factual complexity of determining domicile for individuals, like college students, who have connections to multiple states. The decision serves as a cautionary tale for plaintiffs, demonstrating that ambiguity or an evidentiary tie regarding domicile will be resolved against exercising jurisdiction, forcing the case into state court.
