Arcangel v. Huntington Atlantic Hotels, LLC, 2018 WL 5885517 (2018)

Facts

  • Gilbert and Marygrace Arcangel stayed as guests at a Marriott-branded hotel owned by Huntington Atlantic Hotels, LLC.

  • The Arcangels alleged they were bitten by bedbugs while staying in their room.

  • After the Arcangels complained, the hotel involved its pest-control contractor, Ecolab, Inc., to address the alleged infestation.

  • The Arcangels alleged Ecolab failed to properly inspect and exterminate the bedbugs.

  • The Arcangels sued in Maryland state court and asserted:

    • Count I: negligence against Huntington for placing them in an allegedly infested room;
    • Count II: violation of the Maryland Consumer Protection Act (MCPA) against Huntington, based on an implied representation that the room was fit to occupy; and
    • Count III: negligence against Ecolab for allegedly failing to properly inspect and exterminate.

  • The complaint sought $75,000 in damages for Count I and $75,000 in damages for Count II against Huntington.

  • Huntington and Ecolab removed the case to the U.S. District Court for the District of Maryland based on diversity jurisdiction, arguing the amount in controversy exceeded $75,000 because the two $75,000 demands against Huntington totaled $150,000.

  • The Arcangels moved to remand, disputing that the amount in controversy requirement was satisfied.

Issues

  1. Whether the removing defendants carried their burden to show, by a preponderance of the evidence, that the amount in controversy exceeded $75,000 under 28 U.S.C. § 1332(a).
  2. Whether the $75,000 damages requests in the negligence count and the MCPA count against Huntington could be aggregated, or instead reflected alternate theories seeking one recovery for the same alleged bedbug-related injury.

Decision

  • The court granted the motion to remand.
  • The court concluded the removing defendants did not establish that more than $75,000 was in controversy.
  • The court treated the negligence and MCPA counts against Huntington as alternate routes to recover for the same alleged harm, rather than separate claims supporting separate, stackable awards for amount-in-controversy purposes.
  • Because the defendants relied principally on adding the two per-count $75,000 demands, and that addition did not establish a legally supported amount exceeding $75,000, the court returned the case to state court.

Legal Principles

  • A removing defendant bears the burden to show federal subject-matter jurisdiction, including satisfaction of the amount-in-controversy requirement in a diversity removal.
  • The amount in controversy is evaluated based on the record at the time of removal, and doubts about removal jurisdiction are resolved in favor of remand.
  • A single plaintiff may aggregate multiple claims against a single defendant to reach the jurisdictional threshold only when the pleading places separate, non-duplicative recoveries in dispute; amounts tied to alternate theories for a single injury are not added together simply because they appear in separate counts.
  • When a complaint’s damages requests by count appear directed to one compensatory recovery for one set of alleged injuries, the removing party must provide more than arithmetic addition of per-count demands to prove the jurisdictional minimum.

Conclusion

The district court remanded the action to Maryland state court because Huntington and Ecolab did not show that the amount in controversy exceeded $75,000; the court viewed the $75,000 negligence and $75,000 MCPA demands against Huntington as alternate theories seeking one recovery for the same alleged bedbug-related injury rather than separate sums that could be aggregated to create federal diversity jurisdiction.