Louisiana Supreme Court Clarifies City Courts’ Jurisdictional Limit in Civil Cases

The Louisiana Supreme Court recently provided guidance on the jurisdictional limit for proper filings in Louisiana civil courts. At issue in the case of Thompson v. State Farm was the jurisdictional limit required for proper filing in city court. While filing may seem to the unknowing person on the street like a minor issue, a failure to file a case in the correct district can have dire consequences for the case of a well-intending plaintiff.

In Thompson, the plaintiff sought damages from injuries she sustained in a rear-end chain reaction collision allegedly caused by a driver insured by State Farm. In her filing, she named the driver at fault and State Farm as defendants. Thompson’s husband joined the suit and sought damages for loss of consortium, medical expenses, and loss of his wife’s income due to the injuries she suffered. In their petitions, which were filed in Alexandria City Court, the plaintiffs explicitly demanded an amount “less than the jurisdictional maximum of [the] court.” The Alexandria City Court entered judgment for the plaintiff, awarding her $50,000 in general damages and her husband $20,000 for loss of consortium and $30,000 for past and future medical expenses on behalf of the community. Subsequently, State Farm filed an exception for lack of subject matter jurisdiction, arguing that it was improper for the city court to have heard the case since the amount of damages awarded exceeded the court’s jurisdictional limit of $50,000. The appellate court agreed, vacating the judgment and remanding the case to the lower court in order to transfer the action to a court of competent jurisdiction.

The Louisiana Supreme Court reversed the ruling, finding that the test for subject matter jurisdiction of a city court is the amount in dispute, or the amount demanded by the plaintiff. According to the Louisiana Code of Civil Procedure, the Alexandria City Court has concurrent jurisdiction with the district court in civil cases where the amount in dispute does not exceed $50,000, exclusive of interest and costs. Since both plaintiffs unequivocally limited the amount demanded to “an amount less than the jurisdictional maximum of… yet within the jurisdictional limits of [the Alexandria city] court,” the Supreme Court concluded that the city court had proper subject matter jurisdiction over the case. Accordingly, the Supreme Court reinstated the trial court’s judgment but remanded the case on another issue.

Thompson v. State Farm demonstrates the importance of filing suit in a proper court, which entails filing the case in a court with subject matter jurisdiction, or power to hear the case. When filing a lawsuit, plaintiffs must initially determine where to file the claim since there are several state trial courts that have jurisdiction over civil cases. As shown by Thompson v. State Farm, if jurisdiction is ever challenged and upheld, the consequences are costly to a plaintiff who may end up losing a favorable judgment or relitigating the matter on jurisdictional grounds. Issues like this demonstrate why hiring the proper attorney, who can navigate these very tricky pitfalls, is essential when trying to receive justice for damages suffered caused by someone else.

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