Cleartrac, et al v. Lanrick Contractors, et al, No. 20-30072 (5th Cir. 2022)
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These consolidated appeals involve a dispute over the enforceability of a Texas state court judgment after it had been made executory by a Louisiana state court and the judgment creditors then sought to make it executory in the United States District Court for the Eastern District of Louisiana. That federal court dismissed the case on res judicata grounds, but the Fifth Circuit concluded instead that the district court lacked subject-matter jurisdiction over the case because Plaintiffs failed to satisfy 28 U.S.C. Section 1332(a)’s amount-in-controversy requirement for diversity of citizenship jurisdiction.
Accordingly, the Fifth Circuit vacated the district court’s judgment dismissing Plaintiffs’ complaint on the basis of res judicata and remanded with instructions that the district court dismiss this case without prejudice for lack of subject-matter jurisdiction. The court explained that the $1,313.16 in prejudgment interest awarded in the Texas Judgment is included in determining the amount in controversy. However, the 5.00% interest from the date of the Judgment until paid in full is not. The total amount in controversy thus comes to $58,832.63. Because the amount in controversy does not exceed the sum or value of $75,000, exclusive of interests and costs, the district court lacked subject-matter jurisdiction under Section 1332(a).
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