## Facts

- A minor child and his parents filed separate, related tort claims in federal court arising from an automobile accident, invoking diversity jurisdiction.
- Each plaintiff alleged damages satisfying the then-required $10,000 amount in controversy.
- At pretrial, the district court reviewed the plaintiffs’ pretrial statement describing injuries and itemized expenses.
- The child’s alleged injury was a thoracic lumbar sprain, with medical-related expenses of approximately $136.28 (physicians, hospital, and a back brace) reported several years after the accident.
- The district court concluded that, based on the pretrial record, it appeared to a legal certainty that none of the individual claims could reach $10,000 and dismissed all claims for lack of subject-matter jurisdiction.
- Plaintiffs appealed, arguing that pretrial dismissal misapplied the amount-in-controversy standard and improperly deprived them of a federal jury trial.

## Issues

1. Whether a district court may dismiss, at pretrial, a diversity-based personal injury claim for failure to meet the amount-in-controversy requirement when it appears to a legal certainty the claim cannot reach the jurisdictional minimum.
2. Whether such a pretrial jurisdictional dismissal violates a plaintiff’s statutory right to a jury trial in federal court.

## Decision

- The court of appeals affirmed the dismissal for lack of subject-matter jurisdiction.
- The court held that a district court may examine the pretrial record and dismiss when it appears to a legal certainty that the claim is for less than the jurisdictional amount.
- The court held that dismissal on jurisdictional grounds before trial does not violate any federal jury-trial right because no right to a federal trial exists without federal jurisdiction.
- The court noted its practice of allowing closely related claims to proceed together when at least one claim satisfies the jurisdictional amount, but found no plaintiff had a qualifying “anchor” claim here.

## Legal Principles

- In diversity cases, dismissal for insufficient amount in controversy is proper when it appears to a legal certainty that the plaintiff cannot recover the jurisdictional minimum.
- A court may determine facts necessary to decide jurisdiction and may look beyond pleadings to the pretrial record to assess whether the amount in controversy is genuinely in dispute.
- A federal jury-trial right is contingent on the existence of federal jurisdiction; jurisdictional dismissal does not deprive a party of a jury trial where jurisdiction never attached.
- Related tort claims may be entertained together in federal court when at least one claim independently satisfies the jurisdictional amount, but this doctrine does not apply when none does.

## Conclusion

The Third Circuit upheld pretrial dismissal of related diversity tort claims after reviewing the pretrial record and concluding to a legal certainty that no plaintiff could meet the jurisdictional amount, and it ruled that such dismissal does not infringe a federal jury-trial right because federal jurisdiction is a prerequisite to any federal trial.


Nelson v. Keefer, 451 F.2d 289 (3d Cir. 1971)