Daley v. Amtrak

CourtDistrict Court, S.D. New York
DecidedOctober 29, 2024
Docket7:24-cv-07378
StatusUnknown

This text of Daley v. Amtrak (Daley v. Amtrak) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daley v. Amtrak, (S.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ERIN DALEY, Plaintiff, ORDER

-against- 24-CV-07378 (PMH) AMTRAK; NEW YORK CENTRAL LINES, LLC; and CSX TRANSPORATION, INC., Defendants. PHILIP M. HALPERN, United States District Judge: On September 30, 2024, Defendant CSX Transportation, Inc., (“CSX”) filed a Notice of Removal, removing this action from the Supreme Court of the State of New York, County of Dutchess, to this Court. (Doc. 1, “Not. of Removal”). For the reasons set forth below, this matter is REMANDED to the Supreme Court of the State of New York, County of Dutchess. BACKGROUND On September 30, 2024, CSX filed a Notice of Removal, which attached copies of the following documents: (1) Complaint (Not. of Removal, Ex. A “Compl.”); (2) Registered Mail Receipt as to service of the Complaint (id., Ex. B); (3) State Court docket for this action (id., Ex. C); (4) August 27, 2004 Securities and Exchange Commission Form 8-K for CSX (id., Ex. D); and (5) Notice of Filing of Notice of Removal (id., Ex. E). CSX asserts that this Court has subject matter jurisdiction over this dispute because (1) complete diversity exists between the parties (id. ¶ 20); and (2) the amount in controversy exceeds $75,000, exclusive of interests and costs, because “Plaintiff seeks damages in excess of the jurisdictional limits of all lower courts in the State of New York and has specifically alleged that she was rendered sick, sore, lame, disabled due to the multiple traumatic injuries suffered, whose effects Plaintiff believes are permanent, disabling, and debilitating” (id. ¶ 21).1 ANALYSIS Under 28 U.S.C. § 1441, “any civil action brought in a State court of which the district

courts of the United States have original jurisdiction, may be removed by the defendant . . . .” 28 U.S.C. § 1441(a). “The [federal] district courts shall have original jurisdiction of all civil actions where the matter in controversy exceeds the sum or value of $75,000, exclusive of interest and costs, and is between—(1) citizens of different States.” 28 U.S.C. § 1332(a). “The Supreme Court has held that the party asserting diversity jurisdiction in federal court has the burden of establishing the existence of the jurisdictional amount in controversy.” Villafana v. So, No. 13-CV-00180, 2013 WL 2367792, at *1 (S.D.N.Y. May 29, 2013) (quoting Lupo v. Human Affairs Int’l, Inc., 28 F.3d 269, 273 (2d Cir. 1994)). While defendants need not “prove the amount in controversy to an absolute certainty,” they have “the burden of proving that it appears to a reasonable probability that the claim is in excess of the statutory jurisdictional amount.” Id. (quoting Mehlenbacher v.

Akzo Nobel Salt, Inc., 216 F.3d 291, 296 (2d Cir. 2000)). “[I]f the jurisdictional amount is not clearly alleged in the plaintiff’s complaint, and the defendants’ notice of removal fails to allege facts adequate to establish that the amount in controversy exceeds the jurisdictional amount, federal courts lack diversity jurisdiction as a basis for removing the plaintiff’s action from state

1 On September 30, 2024, CSX filed an Answer (Doc. 9) and attached a stipulation, executed by counsel for Plaintiff and for Defendant Amtrak, stating that Amtrak owned and controlled the area where Plaintiff alleges she was injured. (Doc. 9-1). CSX also attached an email communication wherein it requests that Plaintiff dismiss it from the action. (Doc. 9-2). There is no indication on the docket that Plaintiff has withdrawn its claims against CSX. court.” Id. (quoting Lupo, 28 F.3d at 273-74).2 Federal courts are instructed to “construe the removal statute narrowly, resolving any doubts against removability.” Lupo, 28 F.3d at 274 (quoting Somlyo v. J. Lu-Rob Enters., Inc., 932 F.2d 1043, 1046 (2d Cir. 1991)). Plaintiff’s Complaint alleges that she was injured as a result of Defendants’ negligence

when she slipped on ice on a stairway in the parking lot of the Rhinecliff AMTRAK station. (Compl. ¶¶ 21-25). A plaintiff’s complaint, in an action to recover damages for personal injuries in New York, “shall contain a prayer for general relief but shall not state the amount of damages to which the pleader deems [herself] entitled.” C.P.L.R. § 3017(c). Accordingly, the Complaint does not state a specific sum of money sought from Defendants and asserts only that Plaintiff’s damages “exceed[] the jurisdictional limits of all lower courts which would otherwise have jurisdiction.” (Compl. ¶ 28). If removal of a civil suit from state court to federal court is premised on 28 U.S.C. § 1332(a) and “[s]tate practice . . . does not permit demand for a specific sum,” removal is proper only “if the district court finds, by the preponderance of the evidence, that the amount in controversy exceeds [$75,000].” 28. U.S.C. § 1446(c)(2).

CSX, with respect to the amount in controversy, asserts that Plaintiff’s alleged damages “can fairly be read to exceed the $75,000.00 amount in controversy requirement” because Plaintiff “seeks damages in excess of the jurisdictional limits of all lower courts in the State of New York” and “specifically alleged that she was rendered sick, sore, lame, disabled due to the multiple traumatic injuries suffered, whose effects Plaintiff believes are permanent, disabling, and debilitating.” (Not. of Removal ¶¶ 21-22). CSX fails to meet its burden to show that the $75,000 jurisdictional amount required for diversity jurisdiction has been satisfied.

2 Federal courts “have an independent obligation to determine whether subject-matter jurisdiction exists, even in the absence of a challenge from any party.” Nguyen v. FXCM Inc., 364 F. Supp. 3d 227, 237 (S.D.N.Y. 2019) (quoting Arbaugh v. Y & H Corp., 546 U.S. 500, 514 (2006)). “[N]either the Complaint nor the Notice of Removal ‘contains sufficient information specifying the nature and extent of Plaintiff’s injuries that would permit this Court to draw a reasonable inference that the amount-in-controversy requirement has been satisfied.’” Muniz v. CVS Albany, L.L.C., No. 21-CV-08179, 2021 WL 4596539, at *2 (S.D.N.Y. Oct. 6, 2021) (quoting

Brown v. NutriBullet, LLC, No. 19-CV-05421, 2019 WL 5287960, at *2 (E.D.N.Y. Oct. 18, 2019)). CSX has not furnished any written indication of the amount in controversy. (See generally Not. of Removal). This Court, although not required to do so, has also undertaken to review the electronic docket in the state court proceeding. That docket is devoid of any written indication of the amount in controversy. (See Index No. 2024-53661, NYSCEF Doc. Nos. 1-8). Thus, as federal courts are instructed to “construe the removal statute narrowly, resolving any doubts against removability,” Lupo, 28 F.3d at 274 (quoting Somlyo, 932 F.2d at 1046), CSX’s conclusory allegation that the amount in controversy can fairly be read to exceed $75,000 is insufficient for the Court to determine by a preponderance of the evidence that the jurisdictional threshold of 28 U.S.C. § 1332(a) has been met.

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Related

Arbaugh v. Y & H Corp.
546 U.S. 500 (Supreme Court, 2006)
Pietrangelo v. Alvas Corp.
686 F.3d 62 (Second Circuit, 2012)
Payne v. Overhead Door Corp.
172 F. Supp. 2d 475 (S.D. New York, 2001)
Mehlenbacher v. Akzo Nobel Salt, Inc.
216 F.3d 291 (Second Circuit, 2000)
Nguyen v. FXCM Inc.
364 F. Supp. 3d 227 (S.D. Illinois, 2019)

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Bluebook (online)
Daley v. Amtrak, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daley-v-amtrak-nysd-2024.