WESTCHESTER FIRE INSURANCE COMPANY
v.
STAR LEASING COMPANY

M.D. Fla. | 2021-07-17
District Court, M.D. Florida (2021)

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Holding

The court held that it lacked subject matter jurisdiction because the plaintiff's claims arose under state law and the amount in controversy did not meet the statutory threshold for diversity jurisdiction.

Facts & Procedural History

Plaintiff sued defendants for breach of contract and negligence arising from a trailer rental. The court questioned its subject matter jurisdiction an…

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Topics
Graves Amendment (49 U.S.C. § 30106) Graves Amendment 49 U.S.C. § 30106 Federal Law

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Opinion of the Court

Plaintiff Westchester Fire Insurance Company, as subrogee of Eddie’s Trucking, LLC, brings claims for breach of contract and negligence arising from an incident involving a trailer Eddie’s Trucking rented from Defendants to transport1,512 cases of beer from Tampa, Florida, to Philadelphia, Pennsylvania, in 2019. (Doc. 1). On July 6, 2021, the Court ordered Plaintiff to show cause as to why this action should not be dismissed due to a lack of subject matter jurisdiction. (Doc. 6). Upon review of Plaintiff’s response and the Complaint, this case is dismissed because the Court lacks subject matter jurisdiction. Federal courts are courts of limited jurisdiction and therefore have an obligation to inquire into their subject matter jurisdiction regardless of whether the parties have challenged its existence. See Kirkland v. Midland Mortg. Co., 243 F. 3d 1277, 1279–80 (11th Cir. 2001). Here, as the bases for jurisdiction, Plaintiff cites 28 U.S.C. § 1331, which provides that federal district courts have jurisdiction over civil actions involving a federal question, and 28 U.S.C. § 1337, which provides that federal district courts have jurisdiction over actions “arising under any act of Congress regulating commerce or protecting trade and commerce against restraints an monopolies.” Both provisions, however, require a cause of action arising under federal law, which is notably absent here. Indeed, Plaintiff brings claims only for breach of contract and negligence—actions arising under state law. To make matters worse, even if Plaintiff wished to invoke this

Court’s diversity jurisdiction which enables this Court to hear state law claims,1 the sought-after damages, $26,995.58 plus costs and interest, are far below the $75,000 amount in controversy required by statute. See 28 U.S.C. § 1332.

Plaintiff contends that the Court has subject matter jurisdiction because the trailer lease is subject to federal law and because Defendants have leased a vehicle to be used in interstate commerce. But merely being subject to federal law in the course of business is not enough to confer jurisdiction onto this Court. The cause of action must arise under federal law. See 28 U.S.C. § 1331. While Plaintiff correctly points out that Congress’s power to regulate interstate commerce under current Supreme Court precedent is broad, Congress’s power to legislate under Article I of the Constitution is

yiY Kimball Mizelle United States District Judge

Footnotes
1 It appears that the parties are sufficiently diverse to meet the requirements of 28 U.S.C. § 1332. not the same question as whether federal courts have jurisdiction under Article II] of the Constitution. While Congress may have properly regulated the trailer in this case, its power to do so has no bearing on this Court’s jurisdiction unless and until a plaintiff brings a claim under one of those properly enacted laws. Plaintiff cites the Graves Amendment, a federal tort reform statute that exempts the owners of motor vehicles leased and operated in interstate commerce from certain vicarious liability suits, as potentially preempting any tort claims against Plaintiff, the lessor of the trailer in the instant action. See 49 U.S.C. § 30106. But there are no tort claims pending against Plaintiff to preempt, and even if one might arise in response, the Court is bound to determine jurisdiction “on the face of the plaintiffs properly pleaded complaint.” Dunlap v. G&L. Holding Group, Inc., 381 F. 3d 1285, 1290 (11th Cir. 2004). Because the Court lacks subject matter jurisdiction to hear Plaintiffs state law claims, this action is DISMISSED without prejudice. The Clerk is directed to terminate all pending motions and CLOSE this case. ORDERED in Tampa, Florida, on July 17, 2021.

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