Bell v. Preferred Life Assur. Soc'y - 320 U.S. 238 (1943)
U.S. Supreme Court
Bell v. Preferred Life Assur. Soc'y, 320 U.S. 238 (1943)
Bell v. Preferred Life Assurance Society
Argued October 12, 13, 1943
Decided November 8, 1943
320 U.S. 238
1. Where both actual and punitive damages are recoverable under a complaint invoking the jurisdiction of the federal district court on the ground of diversity of citizenship, each must be considered to the extent claimed in determining whether the jurisdictional amount is involved. P. 320 U. S. 240.
2. A complaint in a federal district court, invoking jurisdiction on the ground of diversity of citizenship, alleged that the plaintiff had been induced to purchase a certificate of insurance through fraudulent misrepresentations by the defendants' agent as to the value, and claimed $200,000 as actual and punitive damages. The record showed that the plaintiff had paid $202.35 on the certificate, which had a maximum potential value of $1,000.
(1) Whether the decision be controlled by the law of Alabama, where the certificate was issued and mailed, or by the law of South
Carolina, where the alleged fraudulent misrepresentations were made, and even though recovery of actual damages be limited to $1,000, the plaintiff's allegations of fraud, if properly proved, might justify an award exceeding $3,000, and therefore the requisite jurisdictional amount was involved. Pp. 320 U. S. 240-241.
(2) The complaint sufficiently alleged the equivalent of "gross fraud," within the meaning of the law of Alabama, even though the fraud was not formally alleged to be "gross." P. 320 U. S. 241.
(3) This Court is unable to say that the Alabama law as to punitive damages precludes in this case a verdict for actual and punitive damages exceeding $3,000. P. 320 U. S. 242.
(4) The question of jurisdictional amount cannot be determined on the assumption that a verdict for that amount would be excessive, and could be set aside. P. 320 U. S. 243.
3. A complaint filed in a federal court should not be dismissed for want of jurisdiction merely because of a technical defect such as may be the subject of a special motion to clarify. P. 320 U. S. 242.
131 F.2d 516 reversed.
Certiorari, 318 U.S. 755, to review the affirmance of a judgment dismissing a suit brought in the District Court on the ground of diversity of citizenship.