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149043 - Hodge v State Farm Mutual Auto Ins Co

Linda C. Hodge,
Michael H. Fortner
Richard E. Shaw 
(Appeal from Ct of Appeals)
(Wayne – Sullivan, B.)
State Farm Mutual Automobile Ins Co.,
Stacey L. Heinonen


This case concerns the jurisdiction of the district court when a plaintiff presents evidence and argument of damages in excess of the district court’s $25,000 jurisdictional limit. The issues to be addressed include: (1) whether a district court is divested of subject-matter jurisdiction when a plaintiff alleges less than $25,000 in damages in his or her complaint, but seeks more than $25,000 in damages at trial, i.e., whether the "amount in controversy" exceeds $25,000 under such circumstances; and, if not, (2) whether such conduct nevertheless divests the district court of subject-matter jurisdiction on the basis that the amount alleged in the complaint was made fraudulently or in bad faith.