Freeland v. Liberty Mut. Fire Ins. Co.
United States Court of Appeals for the Sixth Circuit
632 F.3d 250 (6th Cir. 2011)
The Freelands (plaintiffs) held a Liberty Mutual (defendant) auto policy with $100,000 bodily-injury coverage and separate $25,000 uninsured/underinsured motorist (UM/UIM) coverage. After their uninsured son caused a fatal accident driving their car, Liberty Mutual offered only the $25,000 UM/UIM payout; the Freelands sued in federal court under diversity jurisdiction, seeking a declaration that they were entitled to the full $100,000 bodily-injury coverage instead.
Whether the amount in controversy for purposes of diversity jurisdiction in a declaratory judgment action is measured by the value of the consequences resulting from the litigation, rather than the total amount of coverage sought.