Sunday, November 24, 2013

Caterpillar Inc. v. Lewis case brief

Caterpillar Inc. v. Lewis case brief summary
519 U.S. 61 (1996)


CASE SYNOPSIS
Petitioner corporation filed a writ of certiorari from a judgment from the United States Court of Appeals for the Sixth Circuit granted for respondent employee, which vacated the federal district court judgment rendered for petitioner because complete diversity for subject matter jurisdiction was lacking when the district court allowed the removal of petitioner's personal injury action based on state law from a state court.

CASE FACTS
Petitioner corporation applied for a writ of certiorari from the judgment of the court of appeals rendered for respondent employee that vacated the district court judgment based on the jury verdict in favor of petitioner on the grounds that complete diversity of citizenship for proper subject matter jurisdiction was absent when the district court permitted the removal, from the state court, of petitioner's personal injury action premised on state law. The court granted the writ as requested by petitioner.

DISCUSSION

  • The court reversed the judgment from the court of appeals and remanded the cause. 
  • The court held that the district court's error in failing to remand respondent's lawsuit after it was improperly removed was not fatal to the subsequent adjudication because the federal jurisdictional requirements were satisfied when the judgment was entered. 
  • The court found that the jurisdictional defect of one nondiverse party, which existed when petitioner requested removal, was cured by an intervening settlement agreement reached by the nondiverse party. 
  • Thus, the district court had complete diversity before the trial occurred between petitioner and respondent, who were both diverse parties.
CONCLUSION
The court granted certiorari to petitioner corporation. The court reversed the judgment of the court of appeals entered for respondent employee, which had vacated the federal district court judgment imposed for petitioner due to the absence of complete diversity for subject matter jurisdiction after the removal of petitioner's personal injury action based on state law. The court remanded this matter because the defect was cured before the trial.

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