Hamilton v. Mike Bloomberg 2020, Inc.

Michael Bloomberg sought the Democratic nomination for president in 2020. He hired Melinda Hamilton and other employees (collectively, the employees) (plaintiffs) to work on his campaign, Mike Bloomberg 2020 (the campaign) (defendant). In March 2020, Bloomberg suspended the campaign and terminated the employees. The employees each sued the campaign in Texas state court for owed wages in the amount of $42,000 per employee. The employees also claimed other damages in unspecified amounts, such as lost wages, lost health insurance, lost earning capacity, and mental anguish, among other claims. The campaign removed the case to federal district court, invoking the court’s diversity jurisdiction. The employees moved to remand the case to state court and included signed declarations agreeing to limit damages to $75,000. The campaign produced letters from the employees’ attorneys proving that the employees had already incurred $10,000 each in legal fees. The campaign also produced evidence from similar cases indicating that the employees’ claims for unspecified damages, aside from the $42,000 claimed in owed wages, would exceed $23,000. Therefore, the campaign asserted, total damages would exceed $75,000. The federal district court denied remand and ultimately granted summary judgment to the campaign. The employees appealed, challenging the court’s subject-matter jurisdiction. On appeal, the campaign argued that it had proved by a preponderance of the evidence that the amount in controversy exceeded the jurisdictional requirement. The employees argued that because they swore to limit damages to $75,000, the amount in controversy could not meet the jurisdictional requirement.