## Facts

- Helen J. Wodecki, a Pennsylvania citizen, sued Nationwide Insurance Co. in federal court on diversity grounds seeking payment of health-insurance benefits for hospitalization at Hamot Medical Center.
- A jury returned a verdict for Wodecki in the amount of $8,200, and the court entered judgment on that verdict.
- After judgment, Hamot Medical Center (a Pennsylvania hospital) asserted that Wodecki had assigned to Hamot her rights to receive insurance benefits and sought to intervene in the federal action to protect its claimed interest in the insurance proceeds.
- Hamot also filed a separate Pennsylvania state-court action against Wodecki to recover payment for the same hospitalization expenses.
- Wodecki moved to dismiss Hamot’s intervention claim, arguing the federal action was effectively concluded and the court lacked subject-matter jurisdiction over Hamot’s claim due to lack of complete diversity and failure to meet the then-applicable amount-in-controversy requirement.

## Issues

1. Whether Hamot was entitled to intervene as of right under Federal Rule of Civil Procedure 24(a)(2) in a diversity case after judgment based on an alleged assignment of benefits.
2. Whether permissive intervention under Rule 24(b) was available when the intervenor’s claim lacked an independent basis for federal subject-matter jurisdiction (including complete diversity and the jurisdictional amount).
3. Whether the post-judgment posture and parallel state litigation warranted dismissal of the intervention claim.

## Decision

- The court granted Wodecki’s motion to dismiss Hamot’s claim for intervention.
- The court held that permissive intervention requires independent grounds for federal jurisdiction, and Hamot’s claim lacked such jurisdiction.
- The court declined to proceed with intervention in a concluded case, noting the inefficiency and duplication created by Hamot’s pending state-court suit.
- The judgment for Wodecki against Nationwide for $8,200 remained undisturbed.

## Legal Principles

- Rule 24(b) permissive intervention is procedural and does not supply federal subject-matter jurisdiction; an intervenor must show an independent jurisdictional basis for its claim.
- In diversity cases, subject-matter jurisdiction requires complete diversity of citizenship and satisfaction of the statutory amount in controversy applicable at the time.
- Courts may consider the posture of the case (including post-judgment status) and the existence of parallel state proceedings when determining whether intervention should proceed, particularly where intervention would expand a concluded action into a separate non-diverse dispute.

## Conclusion

The court dismissed a hospital’s post-judgment intervention attempt in a diversity insurance case because the hospital’s claim lacked an independent basis for federal jurisdiction and would have added duplicative litigation better addressed in parallel state-court proceedings.


Wodecki v. Nationwide Ins. Co., 107 F.R.D. 118 (W.D. Pa. 1985)