Missouri Federal Court Dismisses Auto Accident Lawsuit for Lack of Subject Matter Jurisdiction: Blunt v. Farmers Insurance Company

Latest News
Home / Blog / Missouri Federal Court Dismisses Auto Accident Lawsuit for Lack of Subject Matter Jurisdiction: Blunt v. Farmers Insurance Company

by | Oct 27, 2012 | Auto Accidents

A federal judge in Missouri dismissed a lawsuit arising out of a car accident, Blunt v. Farmers Insurance Company, finding that the court lacked subject matter jurisdiction over the case. A woman who suffered injuries in an accident sued the other driver and the other driver’s insurance company in the Eastern District of Missouri. The court considered multiple motions, including motions to dismiss by both defendants and a motion to amend the petition by the plaintiff, and found that the plaintiff had not met the requirements for diversity jurisdiction.

Defendant Chad Berendzen was allegedly involved in a car accident in which his vehicle struck the vehicle driven by the plaintiff, Genorval Blunt. Blunt was unsuccessful, she claimed, in obtaining a settlement from Berendzen’s insurer, Farmers Insurance Company. She filed suit against both Berendzen and Farmers in February 2012, alleging negligence against Berendzen and bad faith refusal to settle a claim against Farmers. Blunt is seeking $100,000 or more in damages.

Berendzen filed a motion to dismiss the suit, arguing that the U.S. District Court lacks subject matter jurisdiction because he and Blunt both resided in Missouri. Farmers also filed a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), asserting that the plaintiff did not state a cause of action for which the court could grant relief. The plaintiff did not plead any facts in her complaint, Farmers alleges, that would give her a cause of action against it, other than a statement that it was Berendzen’s insurer. Upon considering Berendzen’s motion to dismiss, the court found that it lacked subject matter jurisdiction, so it did not address the other motions at length.

Federal law limits the subject matter jurisdiction of U.S. District Courts to specific types of cases. A federal court may exercise diversity jurisdiction, a form of subject matter jurisdiction, when the plaintiff and defendant are citizens of different states and the amount in controversy in the case is greater than $75,000. Citizenship of a state in this context generally refers to the state where a party resides. In cases with multiple plaintiffs and multiple defendants, no plaintiff may be a citizen of a state where any defendant is a citizen.

Because Blunt and Berendzen were both citizens of the state of Missouri at the time Blunt filed her lawsuit, the court held that there was no diversity of citizenship in the case. It also found that the amended complaint proposed by the plaintiff would not cure this defect. It therefore ordered the lawsuit dismissed without prejudice, meaning that the plaintiff may refile if she can assert grounds for jurisdiction. The court denied Farmers’ motion to dismiss without prejudice, and it denied Blunt’s motion to amend the pleadings as moot.

Auto accident attorney Doug Horn is an advocate for safe driving in the greater Kansas City area. He represents the rights of people who have suffered injuries or lost loved ones due to the negligent or illegal conduct of others. Contact us today online or at (816) 795-7500 to schedule a free and confidential consultation.