Rowland v. Patterson

882 F.2d 97, 1989 WL 88956
CourtCourt of Appeals for the Fourth Circuit
DecidedAugust 10, 1989
DocketNo. 87-1721
StatusPublished
Cited by54 cases

This text of 882 F.2d 97 (Rowland v. Patterson) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rowland v. Patterson, 882 F.2d 97, 1989 WL 88956 (4th Cir. 1989).

Opinion

PHILLIPS, Circuit Judge:

Maryland law requires medical malpractice claimants to exhaust an arbitration remedy provided by the state as a precondition to bringing any civil action on the claim in state or federal court. The question on this appeal is whether when a rejected arbitration claim is followed by a federal action invoking diversity jurisdiction, diversity is determined by the parties’ citizenship at the time the state arbitration claim was filed or at the time the federal diversity action was later commenced. We hold that citizenship at the time the federal action was commenced by filing a complaint controls, and on that basis vacate the district court’s contrary ruling and its resulting dismissal of this action for lack of diversity jurisdiction.

I

This action is one for medical malpractice brought by plaintiffs Janet Rowland and Donald Rowland against five medical doctors, the appellees on this appeal. Pursuant to Maryland law, the Rowlands were required to file a claim with the Maryland Health Care Claims Arbitration Office (HCAO) as a precondition to bringing a legal action for malpractice in either state or federal court. Md.Cts. & Jud.Proc.Code Ann. § 3-2A-02. HCAO is an administrative agency of the State of Maryland, not a court of law.

The Rowlands filed their claim with the Maryland HCAO on July 16, 1985. At the time they filed this claim, both the Row-lands and the defendants were citizens of Maryland.

On May 6, 1987, the HCAO granted defendants’ motion for summary judgment on the ground that the claim was untimely under the three-year statute of limitations applicable to medical malpractice claims against health care providers in Maryland. Md.Cts. & Jud.Proc.Code Ann. § 5-109.

[98]*98On June 15, 1987, plaintiffs commenced this action by filing their complaint in the United States District Court for the District of Maryland, alleging that they were residents of West Virginia at the time they filed their complaint in federal court. Defendants disputed the plaintiffs’ allegation that on June 15,1987, they were citizens of West Virginia and argued alternatively that in any event the time for determining diversity was July 16, 1985, the date the claim was filed with HCAO.

The district court did not address the disputed issue of the plaintiffs’ citizenship at the time their federal complaint was filed, but dismissed the action on the ground that for diversity purposes the action was commenced on July 16, 1985, when the claim was filed with the HCAO, at which time the parties concededly were not of diverse citizenship. The district court observed that under the Maryland statute the filing of the HCAO claim tolled the state statute of limitations. Concluding that there should not be two dates for commencement of suit, and because of a concern not to “expand” diversity jurisdiction, the court dismissed the action.

This appeal followed.

II

From the beginning of the diversity jurisdiction, the rule in actions commenced by plaintiffs in federal court has been that the citizenship of the parties at the time of commencement of the action determines whether the requisite diversity exists. See Mollen v. Torrance, 22 U.S. (9 Wheat.) 537, 6 L.Ed. 154 (1824); Conolly v. Taylor, 27 U.S. (2 Pet.) 556, 7 L.Ed. 518 (1829). The rule is not derived from nor dependent upon interpretation of either the constitutional source of diversity jurisdiction in Art. Ill, § 2, or its statutory grant in 28 U.S.C. § 1331. Neither text expressly or by implication addresses this interstitial question. The rule is therefore purely a judicial one, announced and reiterated in the earliest Supreme Court cases as an a priori principle, apparently grounded simply in then customary judicial ways of looking at the attachment of jurisdiction and in the obvious necessity to have some clear rule on the matter. See Mollen, 22 U.S. at 539 (Marshall, C.J.) (“It is quite clear, that the jurisdiction of the court depends on the state of things at the time of the action brought_”); Conolly, 27 U.S. at 565 (Marshall, C.J.) (“[A] jurisdiction depending on the condition of the party is governed by that condition as it was at the commencement of the suit.”). This is not the only rule that might validly (so far as any constitutional or statutory constraints are concerned) have been adopted to control on the point, but its reliability as a convenient bright-line mechanical rule that is clearly compatible with general notions of the attachment of jurisdiction has assured its uninterrupted continuation from the beginning. See generally 13B C. Wright, A. Miller, & E. Cooper, Federal Practice and Procedure § 3608 (1984) (hereinafter Wright, Fed.Prac.).

While over time there have been various ways in which a federal action could be “commenced,”1 since 1938 civil actions are, per the civil rules, commenced by “filing a complaint with the court.” Fed.R.Civ.P. 3. Since the official Rule’s adoption therefore, this public act of filing has fixed the time of commencement of federal civil actions, hence the convenient and reliable reference point for determining the existence of diversity under the broader, antecedent “time of commencement” rule.

We make these obvious points simply to indicate that the basic rule is one of federal interstitial common law, judicially created, grounded in policy and necessity rather than in any constitutional or statutory commands or constraints. And to make the further point that a routine application of the basic rule as now made act-specific by Rule 3 would require that diversity be determined as of the time the federal complaint in this action was filed rather than, as the district court held, the time that the earlier state arbitration claim was filed.

[99]*99III

The best way to address the jurisdictional issue here is by considering the arguments made by appellees for not applying the basic rule as now made act-specific by Rule 3. There are essentially two arguments as we understand the appellees’ position. The first is that application of the federal time of commencement rule here “would violate well established principles of Maryland’s substantive law,” hence, presumably, the principle of Erie R.R. v. Tompkins, 304 U.S. 64, 58 S.Ct. 817, 82 L.Ed. 1188 (1938). Appellees’ Brief at 6.2 The second, and alternative argument is that even if a federal rule fixing the time for determining diversity is applicable, the appropriate federal rule is that applied in removal cases, which looks to the time of commencement of any prior “action before a state tribunal.” Appellees’ Brief at 15.

We take these in order and also consider a third argument that may be implicit in appellees’ position.

A

There is no Erie problem here. It is true that Maryland’s statutory requirement of arbitration as a precondition to legal action has substantive aspects which, under Erie, must be honored by federal courts. Most critically, the precondition itself must be enforced by those courts. We have so held. Davison v. Sinai Hosp. of Baltimore, Inc., 462 F.Supp. 778 (D.Md.1978), aff'd,

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882 F.2d 97, 1989 WL 88956, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rowland-v-patterson-ca4-1989.