United Services Automobile Ass'n v. Brite
50 Tex. Sup. Ct. J. 379, 215 S.W.3d 400, 2007 Tex. LEXIS 87 (2007)
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Rule of Law:
The 'amount in controversy' for determining a court's subject-matter jurisdiction is calculated based on the total value of damages a plaintiff seeks to recover in their petition at the time of filing. This calculation must include all categories of alleged damages, such as future lost wages (front pay), regardless of their speculative nature or the plaintiff's likelihood of recovery.
Facts:
- James Steven Brite was employed by United Services Automobile Association (USAA) from 1977 to 2001.
- In 2001, USAA implemented a reduction in force and terminated Brite’s employment.
- Brite believed he was selected for the layoff and terminated because of his age.
- As a result of his termination, Brite claimed damages for past lost wages ('back pay') and the present value of anticipated future lost wages ('front pay').
Procedural Posture:
- James Steven Brite filed an age-discrimination lawsuit against United Services Automobile Association (USAA) in the Bexar County Court at Law No. 7, a trial court of limited jurisdiction.
- Brite's amended petition sought $1.6 million, and a discovery response clarified his front pay claim alone was approximately $1,000,000.
- USAA filed a plea to the jurisdiction, arguing the amount in controversy exceeded the trial court's $100,000 statutory limit.
- The trial court denied USAA's plea.
- Following a jury trial, the court entered a judgment for Brite totaling over $900,000.
- USAA, as appellant, appealed the judgment to the intermediate court of appeals.
- The court of appeals, with one justice dissenting, affirmed the trial court's judgment, holding that the speculative nature of front-pay damages allowed their exclusion from the jurisdictional calculation.
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Issue:
Does the 'amount in controversy' for determining a county court at law's subject-matter jurisdiction include speculative future damages, such as front pay, that are alleged in the plaintiff's petition?
Opinions:
Majority - Justice Medina
Yes, the 'amount in controversy' for determining a county court at law's subject-matter jurisdiction includes speculative future damages like front pay. The court reasoned that jurisdiction is determined by the amount the plaintiff seeks to recover, as 'alleged on the face of the petition,' not the amount they are likely to actually win. The relevant jurisdictional statute explicitly excludes certain damages (like interest, punitive damages, and attorney’s fees) from the calculation, but it does not exclude front pay. Citing the doctrine of 'expressio unius est exclusio alterius' (the inclusion of a specific limitation excludes all others), the court concluded that because front pay was not on the list of exclusions, it must be included in the jurisdictional calculation.
Analysis:
This decision solidifies a bright-line rule for determining the amount in controversy, prioritizing the plaintiff's good-faith pleadings over a pre-trial assessment of the merits or certainty of damages. It promotes judicial efficiency by preventing mini-trials on the speculative nature of damages simply to establish jurisdiction. This holding compels plaintiffs to be precise in their pleadings, as over-pleading damages in a court of limited jurisdiction can lead to dismissal for lack of jurisdiction, even if the individual damage claims are legally valid.
