Sykes v. Cook Incorporated

Ct. of Appeals vacated Dist. Ct.’s granting of defendant’s summary judgment with respect to plaintiffs’ actions that were consolidated in multidistrict litigation, where plaintiffs alleged that they were injured by defective vena cava filter device manufactured by defendants. Ct. of Appeals found that Dist. Ct. lacked diversity jurisdiction to act on said complaints, because neither plaintiff could establish $75,000 amount-in-controversy requirement for diversity jurisdiction. Under “legal certainty” test plaintiffs’ allegations about amount in controversy control unless court concludes to legal certainty that face of pleading demonstrates that plaintiff cannot recover jurisdictional minimum or that proofs show that plaintiff never was entitled to recover said amount. Under relevant state laws, neither plaintiff could make required showing, where, at time they had filed their complaints: (1) both plaintiffs alleged only that they suffered asymptomatic IVC perforation of their veins that was caused by defective filter; (2) neither plaintiff could allege in good faith that they experienced pain or other compensable symptoms arising out of defective filter or that they were at risk of future injury; and (3) relevant state courts would find that $75,000 verdict for either plaintiff would be excessive under instant circumstances.