CATERPILLAR INC.v. JAMES DAVID LEWIS
CATERPILLAR INC. V. JAMES DAVID LEWIS
FACTS: Plaintiff respondent Lewis is a Kentucky resident who suffered personal injuries while in the course of operating a bulldozer. Lewis filed a claim for damages before the Kentucky state court against the two defendants: the manufacturer and the company that provided service for the maintenance of the bulldozer. The manufacturer is Caterpillar, is a company incorporated in Delaware, Illinois. While Whayne Supply Company is the company providing service to the bulldozer was incorporated in Kentucky, and having its principal place of business Kentucky. The plaintiff entered into a settlement agreement with the servicer. On the other hand, Caterpillar filed a notice of removal in the District of Kentucky, claiming that the settlement had established a diversity of citizenship in order to maintain federal jurisdiction of the case and to render it removable. Lewis has filed an opposition to the remove to remand the case to state court by arguing that the insurance company filed a motion to intervene by asserting that the subrogation claims against the servicer and the manufacturer for failure to settle its claim against the servicer; and rendering the complete diversity completely absent. The District Court denied the motion to remand filed by the Lewis. On the other hand, the insurance company and the servicer entered into a settlement of the subrogation claim, ordering the dismissal of the servicer from the lawsuit, making the manufacturer as the sole defendant.
PROCEDURAL HISTORY : The District Court denied the motion to remand filed by the plaintiff. While on appeal, the Court of Appeals for the Sixth Circuit reversed judgment ruling that diversity was not fully satisfied at the time of removal so the servicer, Whayne Supply Company should remain a party in the subrogation claim of the insurance company and (2) The lower court committed an error in the denial of the motion to remand by Lewis.
While the case was appealed on certiorari, Supreme Court reversed the ruling of the Court of Appeals and remanded the case for further proceedings.
ISSUE : Whether or not the Court of Appeals was correct in ruling that the diversity was not fully satisfied at the time of removal so the servicer should remain a party in the subrogation claim of the insurance company and (2) The lower court committed an error in the denial of the motion to remand by plaintiff
RULING: The error committed by the lower court when it failed to remand the case as being improperly removed cannot be considered as fatal to the pending adjudication provided that federal jurisdictional requirements have been satisfied during the time judgment is entered. The ruling in this case is that complete diversity is present and did not exist at time of removal, but was present when judgment was entered.
APPLICATION/ANALYSIS: The plaintiff who was able to file a timely objection to remove the case from a state court to a Federal District Court cannot be challenged successfully through the adverse judgment of the District Court on the basis that that the removal was not able to satisfy the statutory prescriptions with regard to the diversity jurisdiction, in the event that the plaintiff filed a case against two defendants before the district court claiming diverse citizenship and that the defendant with diversity files a notice of removal under federal.
CONCLUSION: The error of the district court when it failed to remand a case improperly removed cannot be considered as fatal to the ensuing adjudication since the federal jurisdictional requirements have been complied with during the moment that the judgment was rendered. There was no jurisdictional defect that lingered through judgment in the District Court. The CA committed an error when it remanded the case for trial to state court after having satisfied all the federal jurisdictional requirements. Otherwise it will result to an exorbitant cost to the court system and runs counter with the purpose of having a fair and swift administration of justice (ABA Journal, 1997, p.55).
References
ABA Journal. The Lawyers Magazine, Vol. 1997.
Caterpillar Inc. v. James David Lewis, 519 U.S. 61; 117 S. Ct. 467;
