Coventry Sewage Associates v. Dworkin Realty Co.
United States Court of Appeals for the First Circuit
71 F.3d 1 (1995)
Coventry (plaintiff) sued Stop & Shop (defendant) in diversity for $74,953 in unpaid sewage-service fees, an amount based on water-usage invoices from a third-party water authority that later turned out to have misread Stop & Shop's meters, reducing the true claim first to about $18,667 and then to about $8,485 after partial payment; Stop & Shop moved to dismiss for lack of subject matter jurisdiction because the corrected amount fell below the diversity threshold, and the district court granted the motion.
Whether a federal district court lacks subject matter jurisdiction if a plaintiff, in good faith, establishes the requisite amount in controversy under 28 U.S.C. § 1332 but a subsequent development of which the plaintiff could not have been aware reveals that the amount in dispute actually fails to meet the requirement.