Gentle v. Lamb-Weston, Inc.

A group of nine potato farmers from Maine (the potato farmers) (plaintiffs) sued Snow Flake Canning Co., a Maine corporation, in Maine state court for an alleged breach of contract. After filing their lawsuit, the potato farmers learned that Snow Flake Canning had merged with Lamb-Weston, Inc. (defendant), an Oregon corporation. The potato farmers filed a new lawsuit against Lamb-Weston in Maine state court alleging the same breach of contract. In the second lawsuit, the potato farmers added George O. Tamblyn (plaintiff), an Oregon citizen, as a plaintiff. Tamblyn, a friend of an attorney working for the potato farmers, was assigned 1 percent of each potato farmer’s claim. Tamblyn had no other interest or connection to the case and agreed to take the assignments in order to destroy complete diversity between the parties and prevent the case from being removed to federal court. Lamb-Weston removed the case to federal court regardless. The potato farmers and Tamblyn moved to remand the case to state court, arguing that the federal court could not exercise diversity jurisdiction because complete diversity did not exist. To support their motion, the potato farmers and Tamblyn pointed to a line of cases in which the United States Supreme Court held that plaintiffs may destroy diversity jurisdiction by assigning an entire claim to a nondiverse party in order to prevent a case from being removed to federal court.