Padilla-Mangual v. Pavía Hospital
2008 WL 384321, 2008 U.S. App. LEXIS 3166, 516 F.3d 29 (2008)
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Rule of Law:
When a party's claimed change of domicile for diversity jurisdiction is challenged, a district court generally cannot dismiss the case based solely on written evidence if the party has provided a sworn declaration of intent to remain in the new state and the opposing evidence does not demonstrate the falsity of that declaration with reasonable certainty. In such circumstances, where the declarant's credibility is central to the jurisdictional question, an evidentiary hearing is required.
Facts:
- Ryan Padilla-Mangual was raised and lived in Puerto Rico.
- He received allegedly negligent medical treatment from Dr. Miguel De La Cruz Castellanos at Pavia Hospital in Puerto Rico.
- Padilla-Mangual claimed he permanently relocated from Puerto Rico to Florida on December 31, 2004.
- On January 20, 2005, he obtained a Florida driver's license.
- While living in Florida, Padilla-Mangual did not work, attend school, open any bank accounts, register to vote, or join any clubs or churches.
- His mother, who remained in Puerto Rico, provided him with complete financial support.
- Four days before filing his federal lawsuit, Padilla-Mangual filed a complaint in Puerto Rico state court alleging the same medical malpractice, in which he was described as a resident of Puerto Rico.
Procedural Posture:
- Ryan Padilla-Mangual sued Pavia Hospital and Dr. Miguel De La Cruz Castellanos in the U.S. District Court for the District of Puerto Rico, asserting federal diversity jurisdiction.
- The defendants filed motions to dismiss and for summary judgment, arguing the court lacked subject matter jurisdiction because Padilla-Mangual was domiciled in Puerto Rico, not Florida, meaning there was no diversity of citizenship.
- The district court, relying solely on written submissions and without holding an evidentiary hearing, granted the defendants' motions and dismissed the case.
- Padilla-Mangual, as appellant, appealed the dismissal to the U.S. Court of Appeals for the First Circuit.
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Issue:
Does a district court commit clear error by dismissing a case for lack of diversity jurisdiction based on written evidence alone, without holding an evidentiary hearing, when the plaintiff has submitted a sworn declaration of intent to change domicile and the opposing evidence raises doubts but does not conclusively disprove this declaration?
Opinions:
Majority - Smith, District Judge
Yes. A district court's dismissal under these circumstances is a clear error because when a party's intent is at issue and credibility is central, a decision cannot rest on a paper record alone. To establish a change in domicile, a party must show physical presence in the new state and an intent to remain there. While Padilla-Mangual lacked many of the 'typical indicia' of domicile such as employment, bank accounts, or voting registration, these factors are merely evidence of intent and are not required. He submitted a sworn declaration stating his intent to remain in Florida. The conflicting evidence—primarily the prior state court filing—raised doubts but did not demonstrate the 'falsity of the declaration with reasonable certainty.' Therefore, the issue became one of Padilla-Mangual's credibility, which a district court cannot properly assess without an evidentiary hearing. Dismissing the case without such a hearing was a procedural error requiring reversal and remand.
Analysis:
This case clarifies the procedural requirements for resolving challenges to diversity jurisdiction based on a party's domicile. It establishes that while district courts have discretion in determining jurisdiction, that discretion is not unlimited, especially when a party's subjective intent is the central factual question. The decision emphasizes that a court cannot simply weigh competing paper documents when credibility is key; it must hold a hearing to make a proper credibility determination. This protects a plaintiff's right to access a federal forum by ensuring that jurisdictional challenges based on domicile are not decided on an incomplete or underdeveloped record.
