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Lumbermen's Mutual Casualty Co. v. Elbert

348 U.S. 48, 75 S. Ct. 151, 99 L. Ed. 59 (1954)

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Lumbermen’s Mutual Casualty Co. v. Elbert

United States Supreme Court

348 U.S. 48, 75 S. Ct. 151, 99 L. Ed. 59 (1954)

Facts

Florence R. Elbert (plaintiff), a citizen of Louisiana, was injured in an automobile accident in Louisiana allegedly due to the negligence of Mrs. S. W. Bowen, a Louisiana citizen. Mr. Bowen had an insurance policy through Lumbermen’s Mutual Casualty Co. (Lumbermen’s Mutual) (defendant), an Illinois corporation that did business in Louisiana. Instead of suing Mrs. Bowen for negligence, Elbert sued Lumbermen’s Mutual under Louisiana’s direct-action statute, which allowed an injured party to institute a direct legal action against an insurance company for a wrong done by the insured party. Elbert filed the lawsuit in federal district court, asserting that diversity jurisdiction existed because she was seeking damages that exceeded the amount-in-controversy requirement and because she and Lumbermen’s Mutual held diverse citizenship. The district court dismissed the case for lack of jurisdiction because Elbert and Mrs. Bowen were both Louisiana citizens. The court of appeals reversed, holding that the diversity jurisdiction existed and remanding the case to the district court for trial. The district court found in favor of Lumbermen’s Mutual. The United States Supreme Court granted certiorari to determine whether the federal district court had diversity jurisdiction over the case.

Rule of Law

Issue

Holding and Reasoning (Warren, C.J.)

Concurrence (Frankfurter, J.)

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