Insurance Brokers West, Inc. v. Liquid Outcome, LLC, No. 17-1372 (1st Cir. 2017)Annotate this Case
The First Circuit affirmed the district court’s dismissal of Insurance Brokers West, Inc.’s (IBW) complaint alleging breach of contract against Liquid Outcome, LLC, f/k/a Astonish Results, LLC (Astonish) for failure to meet the amount-in-controversy requirement for diversity jurisdiction under 28 U.S.C. 1332. In its amended complaint, IBW estimated its damages as exceeding $140,000. The district court dismissed the complaint, finding that IBW’s claims did not exceed $75,000, and therefore, IBW failed to meet the amount-in-controversy requirement for diversity jurisdiction. The First Circuit affirmed, holding that it was certain as a matter of law that IBW could not recover more than $75,000.