Proof for federal court
Dart Cherokee Basin Operating v. Owens
In brief
Defendants moving cases to federal court do not have to attach evidence if their notice makes a plausible claim that the amount at stake exceeds the federal threshold.
- Where it stands
- Decided
Decided 5-4 · December 15, 2014 · Opinion by Justice Ginsburg
- What it’s about
- The Supreme Court ruled that Dart Cherokee’s notice moving Owens’s case to federal court needed only a plausible claim that the amount exceeded the federal threshold, not evidence.
- Who it affects
- Defendants seeking to move cases to federal court need only plausibly claim that the amount at stake exceeds the federal threshold; they do not have to attach evidence to the notice.
Summary: written with AI from the case record.
What it's about
It found the district court erred and the Tenth Circuit abused its discretion by denying review, wiped out the Tenth Circuit’s order (vacated it), and sent the case back to that court (remanded).
Owens's case was a class action that Dart Cherokee sought to move from state court to federal court. The district court sent it back to state court because the notice lacked evidence about the amount at stake.
The amount at stake was one requirement for a federal court to hear this class action.
Question presented
Is a defendant seeking removal of a case to federal court required to provide evidence supporting federal jurisdiction in the notice of removal?
What the Court decided
Holding
1. As specified in §1446(a), a defendant’s notice of removal need include only a plausible allegation that the amount in controversy exceeds the jurisdictional threshold; the notice need not contain evidentiary submissions. Section 1446(a) tracks the general pleading requirement stated in Rule 8(a) of the Federal Rules of Civil Procedure. By borrowing Rule 8(a)’s “short and plain statement” standard, corroborative history indicates, Congress intended to clarify that courts should “apply the same liberal rules [to removal allegations as] to other matters of pleading.” H. R. Rep. No. 100–889, p. 71. 2. The District Court erred in remanding this case for want of an evidentiary submission in the notice of removal, and the Tenth Circuit abused its discretion in denying review of that decision. Pp. 7– 14. Vacated and remanded.
- Result
- Vacated
The Court's reasoning
The Court said the law for moving a case to federal court uses the same basic “short and plain statement” standard as other court filings. It concluded that a plausible claim about the amount at stake meets that standard, without evidence attached.
The vote
From the opinions
“I agree with JUSTICE SCALIA that the merits of the District Court’s decision are not properly before the Court.”
What's next
The Tenth Circuit will take another look at Dart Cherokee's request for permission to appeal the district court's order sending the case back to state court.
Documents
Opinions
Docket activity
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More questions
- What did the Tenth Circuit do before the Supreme Court acted?
- It refused Dart Cherokee permission to appeal the district court's order sending the class action back to state court.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.