Avitts v. Amoco Production Co.
53 F.3d 690 · Court of Appeals for the Fifth Circuit · 1995
Facts
Plaintiffs initially sued in Texas state court for property damages from oil and gas operations, vaguely referencing violations of 'Federal law.' Defendants removed the case to federal court based on this reference. Plaintiffs subsequently amended their complaint multiple times, consistently omitting any federal law claims and pursuing only state law causes of action. The federal district court issued interim orders, including a preliminary injunction and an award of costs and attorney's fees.
Procedural history
Appellees originally filed suit in Texas state district court, which was subsequently removed to the Southern District of Texas by the Appellants. The district court then entered interim orders, including a preliminary injunction and an order requiring Appellants to pay approximately $650,000 in interim costs and attorney's fees. Appellants appealed these interim orders to the United States Court of Appeals for the Fifth Circuit.
Issue
Did the federal district court possess subject matter jurisdiction over the plaintiffs' action, given that their complaint, after initial removal, was amended to assert only state law causes of action, and no federal cause of action was ever explicitly pleaded?
Holding
No. The Court of Appeals held that the district court lacked subject matter jurisdiction because no federal cause of action was ever properly asserted. Consequently, the court vacated the district court's interim orders and remanded the case with instructions to dismiss the complaint without prejudice.
Rule
Federal courts have subject matter jurisdiction over cases arising under federal law (federal question jurisdiction). A plaintiff is generally the master of their complaint, and a vague, nebulous reference to 'federal law' or the mention of federal statutes solely for calculating damages is insufficient to establish federal question jurisdiction if no federal cause of action is pleaded.
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