Filla v. Norfolk Southern Railway Company

Mark Filla (plaintiff), a Missouri citizen, filed a lawsuit against Norfolk Southern Railway Company (Norfolk) (defendant), a Virginia citizen, in Missouri state court related to injuries he sustained from a collision with a train at a railroad crossing. Norfolk removed the case to federal court under diversity jurisdiction. Later, Filla amended his complaint to include additional defendants, Skyline Motors, Inc. (Skyline), Richard March, Darlene March, and Patrick Connaughton (defendants), all Missouri citizens. Skyline and the Marches owned land adjacent to the railroad crossing and, according to Filla, failed to maintain the property. Richard died during the court proceedings and was dismissed from the case. Connaughton owned a business near the railroad crossing. Filla claimed that Connaughton was liable for damages because he failed to warn customers of the dangerous conditions at the railroad crossing. Filla filed a motion to remand the case because joining the additional defendants destroyed diversity jurisdiction. The district court held that Filla’s claim against Connaughton had no reasonable basis under state law and that Connaughton was fraudulently joined. Regardless, the district court remanded the case to state court after finding that there was a reasonable basis for Filla’s claims against Skyline and Darlene and that they were not fraudulently joined. Norfolk, Skyline, and Darlene appealed, arguing that the district court should have decided whether the claims truly existed against Skyline and Darlene under state law.