Amer Lung NH v. Amer Lung Asssoc.

2002 DNH 142
CourtDistrict Court, D. New Hampshire
DecidedJuly 25, 2002
DocketCV-02-108-B
StatusPublished

This text of 2002 DNH 142 (Amer Lung NH v. Amer Lung Asssoc.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Amer Lung NH v. Amer Lung Asssoc., 2002 DNH 142 (D.N.H. 2002).

Opinion

Amer Lung NH v. Amer Lung Asssoc. CV-02-108-B 07/25/02

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

American Lung Association of New Hampshire

v. Civil N o . 02-108-B Opinion N o . 2002 DNH 142 American Lung Association, and Director of Charitable Trusts of the N.H. Department of Justice

MEMORANDUM AND ORDER

The American Lung Association of New Hampshire (“ALANH”)

commenced this declaratory judgment action in the Hillsborough

County Probate Court against the American Lung Association

(“ALA”) and the State’s Director of Charitable Trusts

(“Director”). The ALA subsequently removed the action to this

court. At issue is the Director’s claim that the case must be

remanded because the court lacks subject matter jurisdiction.

BACKGROUND

Several years ago, ALANH entered into agreements with ALA,

obligating each organization to share 10% of its “income and

receipts” with the other. The agreements exempt from the sharing requirement both “funds restricted in writing by the donor . . .

to exclude or limit sharing” and “income on investments.”

ALANH received substantial donations from the Margaret L.

Fuller Memorial Trust in 1999 and 2001. The agreement creating

the trust identifies several charitable organizations that are to

receive donations, including ALANH, but specifies that “income

only [is] to be used for their general purposes.” ALANH has

refused to share the trust’s donations with ALA. It argues that

because the above-quoted provision prevents it from using the

donations for anything other than to generate income for its own

purposes, it is not obligated to share the donations with ALA.

It has also refused to share income produced by investing the

donations because it contends that its agreements with ALA do not

obligate it to share investment income.

ALANH, a New Hampshire corporation, commenced the

declaratory judgment action against ALA, a Maine corporation, in

an effort to obtain rulings from the court endorsing its

interpretations of the trust agreement and its agreements with

ALA. It joined the Director as a defendant because the New

Hampshire Supreme Court has determined that the Director is an

indispensable party in actions that involve the enforcement or

supervision of charitable trusts. See Concord Nat. Bank v .

-2- Haverhill, 101 N.H. 416, 419 (1958).

ALA subsequently removed the action to this court without

obtaining the consent of the Director. In doing s o , it invoked

the court’s diversity of citizenship jurisdiction.

ANALYSIS

The principal question presented by this case is whether the

inclusion of the Director as a party prevents the court from

exercising diversity jurisdiction. Several accepted

jurisdictional rules place the question in context. The first is

that for jurisdictional purposes, a plaintiff effectively sues

the state when it sues a state official in his official capacity.

See Northeast Fed. Credit Union v . Neves, 837 F.2d 531, 533 (1st

Cir. 1988). The second is that ordinarily “diversity

jurisdiction does not exist where a state is a party.” U.S.I.

Properties Corp. v . M.D. Const. Co., 230 F.3d 489, 499 (1st Cir.

2000). Relying on these two principles, the Director claims that

the court lacks diversity jurisdiction because ALA sued him in

his capacity as a state official.

ALA invokes a third rule which holds that “a federal court

must disregard nominal or formal parties and rest jurisdiction

-3- only upon the citizenship of real parties to the controversy.”1

Navarro Sav. Ass’n v . Lee, 446 U.S. 458, 461 (1980). It argues

that the Director is not a real party to the controversy because

neither he nor the state has anything to gain or lose in the

case. The Director responds by arguing that he is a real party

to the controversy because the New Hampshire Supreme Court has

determined that he is indispensable. See Concord Nat’l Bank, 101

N.H. at 419.

The short answer to the Director’s argument is that a party

may be indispensable to an action filed in state court without

being a real party to the controversy as that phrase is used in

Navarro.2 This is because the real party to the controversy test

1 The Court recognized in Navarro that while “[t]here is a ‘rough symmetry’ between the ‘real party in interest’ standard of [Fed. R. Civ. P.] 17(a) and the rule that diversity jurisdiction depends upon the citizenship of real parties to the controversy[,] . . . the two rules serve different purposes and need not produce identical outcomes in all cases.” Id. at 462 n.9. Accordingly, in determining that neither the Director nor the State of New Hampshire is a real party to the controversy for jurisdictional purposes, I express no view as to whether either is a real party in interest under Rule 17(a). 2 The New Hampshire Supreme Court’s determination that the Director is indispensable in any state court case that concerns the enforcement or supervision of a charitable trust does not necessarily make the Director an indispensable party in a federal court action addressing the same issues. Whether a party is indispensable in federal court ultimately is a question of federal law governed by Fed. R. Civ. P. 1 9 . See Provident Tradesmens Bank and Trust C o . v . Patterson, 390 U.S. 102, 125

-4- is controlled by federal law. If it were otherwise, a state

court could prevent the federal courts from exercising

jurisdiction over a whole class of state law claims between

otherwise diverse parties merely by requiring that the state also

be named as a party. In this case, the Director has no personal

stake in the outcome. Nor does the state have an interest in the

action apart from its general interest in protecting its citizens

from the misuse of assets donated by a charitable trust. See

Concord Nat’l Bank, 101 N.H. at 419 (noting that “the Attorney

General or his representative represents the public in the

enforcement and supervision of charitable trusts”). Naming a

state official as a party will not deprive the court of diversity

jurisdiction when the state’s only interest in the action is to

protect its citizens because, as the United States Supreme Court

observed in Missouri, Kansas & Texas Ry. C o . v . Hickman:

[i]t is true that the state has a governmental interest in the welfare of all its citizens, in compelling obedience to the legal orders of all its officials, and in securing compliance with all its laws. But such general governmental interest is not that which makes the state, as an organized political community, a party in interest in the litigation, for if that were so the state

(1968). I express no view as to whether a party could be considered indispensable under Rule 19 without also being a real party to the controversy for purposes of diversity jurisdiction.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Princess Lida of Thurn and Taxis v. Thompson
305 U.S. 456 (Supreme Court, 1939)
Provident Tradesmens Bank & Trust Co. v. Patterson
390 U.S. 102 (Supreme Court, 1968)
Navarro Savings Assn. v. Lee
446 U.S. 458 (Supreme Court, 1980)
U.S.I. Properties Corp. v. M.D. Construction Co.
230 F.3d 489 (First Circuit, 2000)
Northeast Federal Credit Union v. Anthony J. Neves
837 F.2d 531 (First Circuit, 1988)
United States v. Joseph Bey, Jr.
188 F.3d 1 (First Circuit, 1999)
Concord National Bank v. Haverhill
145 A.2d 61 (Supreme Court of New Hampshire, 1958)
Miller v. Principal Life Insurance
189 F. Supp. 2d 254 (E.D. Pennsylvania, 2002)
Ramada Inns, Inc. v. Rosemount Memorial Park Ass'n
598 F.2d 1303 (Third Circuit, 1979)

Cite This Page — Counsel Stack

Bluebook (online)
2002 DNH 142, Counsel Stack Legal Research, https://law.counselstack.com/opinion/amer-lung-nh-v-amer-lung-asssoc-nhd-2002.