Caterpillar v. Lewis

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Caterpillar v. Lewis
Court Supreme Court of the United States
Citation 519 U.S. 61
Date argued November 12, 1996
Date decided December 10, 1996
Appealed from 6th Circuit

Facts

  • Caterpillar Inc. = "Caterpillar" = a major American manufacturer of construction equipment including bulldozers
  • Lewis suffered injuries while operating a bullozer.
  • Caterpillar was incorporated in Delaware
  • Whayne Supply Company ("Whayne") = a Kentucky company that serviced the bulldozer
  • Liberty Mutual = the insurance company of the employer of Lewis = a company based in Massachussetts

Procedural History

  • In June 1989, James Lewis, a Kentucky resident, filed a product liability lawsuit in a Kentucky state court.
  • The suit of Lewis was against
    1. Caterpillar &
    2. Whayne Supply Company ("Whayne")
  • Liberty Mutual ("Liberty") brought a subrogation claim against Caterpillar for the workers' compensation benefits that Liberty had paid to Lewis on behalf of his employer
  • Whyane quickly settled the complaint of Lewis within 1 year
    • Whayne was dismissed from the suit after settling Liberty's subrogation claim
  • Caterpillar removed the case to federal district court [at this time, Whayne hadn't settled & was still a Kentucky defendant]
  • The complaint of Lewis went to trial in the federal district court
    • The jury in the federal court ruled in favor of Caterpillar
  • However, Caterpillar lost in the 6th Circuit

Issues

Is the lack of complete diversity at the time of removal fatal to federal court jurisdiction if federal jurisdictional requirements have been satisfied at the time judgment is entered?

Arguments

Lewis sought remand of the case back to state court because he argued that completely diversity was absent herein since Whayne (a Kentucky company) was a party to the lawsuit.

Holding

No; if federal jurisdictional requirements are met at the time judgment is entered, the lack of complete diversity at the time of the removal isn't fatal to federal court jurisdiction.


Ruth Bader Ginsburg: The district court erred in failing to recognize Whayne (a Kentucky company) was still a party at the time of removal. Nevertheless, this court error isn't a big deal & may be over-looked.

Judgment

Reversed the 6th Circuit

Reasons

Ginsburg: At this time, after 3 years of litigation & 6 days of trial, remanding the case back to state court based on a technicality would impose an undue burden & needless costs on the judicial systems at both the federal & state levels.

Rule

Procedural violations of the removal statute aren't fatal to maintaining federal jurisdiction

Resources