Wilfredo Rodriguez-Diaz v. Marcelo Sierra-Martinez
1988 U.S. App. LEXIS 10875, 1988 WL 82197, 853 F.2d 1027 (1988)
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Rule of Law:
For purposes of federal diversity jurisdiction, a person's capacity to acquire a new domicile of choice is determined by federal common law, which looks to whether the person has reached the age of majority in the state where they are physically present and intend to remain, rather than the law of their prior domicile.
Facts:
- Wilfredo Rodriguez Diaz, a 17-year-old domiciliary of Puerto Rico, was involved in a motorcycle accident with Marcelo Sierra Martinez.
- Rodriguez Diaz received medical treatment at two hospitals in Puerto Rico, which he alleged was negligent.
- Following his initial treatment, Rodriguez Diaz was transferred to a hospital in New York City.
- After the accident and between his treatment in Puerto Rico and filing suit, Rodriguez Diaz moved to New York and turned 18.
- At the time of filing his lawsuit, Rodriguez Diaz alleged he was living in New York with the intent to make it his permanent home.
- His parents remained residents and domiciliaries of Puerto Rico.
- The age of majority in Puerto Rico is 21, while the age of majority in New York is 18.
Procedural Posture:
- Wilfredo Rodriguez Diaz filed a complaint for negligence and medical malpractice against Marcelo Sierra Martinez and two hospitals in the United States District Court for the District of Puerto Rico.
- Diaz alleged jurisdiction based on diversity of citizenship, claiming he was a citizen of New York while all defendants were citizens of Puerto Rico.
- The defendants filed a motion to dismiss the complaint for lack of diversity jurisdiction.
- The district court granted the defendants' motion, ruling that under Puerto Rico law, Diaz was a minor whose domicile remained that of his parents in Puerto Rico, thus destroying diversity.
- Diaz, as the appellant, appealed the district court's dismissal to the United States Court of Appeals for the First Circuit.
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Issue:
For the purpose of establishing federal diversity jurisdiction, does a person who is 18 years old have the capacity to establish a new domicile of choice in a state where the age of majority is 18, even though their prior domicile, where their parents still reside, considers them a minor until age 21?
Opinions:
Majority - Campbell, C.J.
Yes, a person who is 18 years old has the capacity to establish a new domicile of choice in a state where that is the age of majority. The determination of a litigant's state citizenship for diversity purposes is controlled by federal common law, not by the law of any single state. The court found that relying on either the law of the prior domicile (Puerto Rico) or the forum state (Puerto Rico) created a logical paradox: one cannot determine capacity without knowing the domicile, and one cannot determine domicile without knowing the capacity. To resolve this, the court adopted a federal rule focusing on the realities of the individual's situation. If a person is physically present in a state, intends to remain there, and has reached the age of majority under that state's law, they can establish a domicile there for diversity jurisdiction, regardless of the law of their previous domicile.
Dissenting - Torruella, J.
No, an 18-year-old in this situation does not have the capacity to establish a new domicile. The analysis should begin with the plaintiff's undisputed original domicile, Puerto Rico. Under Puerto Rican law, an 18-year-old is a minor who lacks the legal capacity to change domicile without formal emancipation. The state has a paramount interest in regulating its minors, and federal courts should not interfere with this state interest by creating a federal common law rule. This ruling inappropriately expands diversity jurisdiction at the expense of significant, non-discriminatory local laws and ignores precedent suggesting that the law of the original domicile should control the issue of capacity.
Analysis:
This case establishes a significant federal common law rule for determining domicile in diversity jurisdiction cases involving a conflict of laws over the age of majority. It prioritizes the law of the individual's new physical residence and intent over the traditional, more rigid rule tying a minor's domicile to that of their parents. This decision reflects a policy of favoring access to federal courts and adopting a practical, reality-based approach over formalistic choice-of-law principles that can lead to circular reasoning. It signals that federal courts will craft uniform rules to serve the specific aims of diversity jurisdiction, even if that means deviating from state law or traditional common law doctrines.
