Products Liability Law Reporter

A federal district court held that it lacked subject matter jurisdiction over a suit claiming liability for a consumer’s alleged injuries from contaminated gummy bears.

Matthew Beckler sued Zachary Confections, Inc., alleging claims for products liability and negligence. The plaintiff alleged that he had consumed gummy bears contaminated with rodent feces, causing him gastrointestinal pain. The defendant removed the case to federal court, citing diversity jurisdiction.

Remanding, the district court found that when a complaint is uncertain or silent on the value of the relief sought, when removing a suit, the defendant must prove the jurisdictional amount by a preponderance of the evidence. Citing case law, the court added that a court may not speculate about the amount in controversy. Moreover, the court said, subject matter jurisdiction is not something that can be thrust upon a district court, consented to, or waived.

The court found that at the time of removal, a $65,000 settlement offer from the plaintiff was the only workable number the court had before it. The plaintiff’s discernable damages amount to approximately $11,500, however, and this is more than $63,000 short of what is needed for the court to have subject matter jurisdiction, the court said. Moreover, the court found that the defendant failed to offer any evidence to support its argument that the value of the plaintiff’s medical expenses would satisfy the amount in controversy requirement. The court noted that it would have to engage in significant speculation and guesswork to reach a sum that exceeded the amount in controversy requirement. It declined to do so, noting that under relevant case law, the jurisdictional amount must be either stated clearly on the face of the documents before the court or readily deduced from them.

Thus, the court held that it lacked subject matter jurisdiction over the case.

Citation: Beckler v. Zachary Confections, Inc., 2024 WL 1050091 (M.D. Ga. Mar. 11, 2024).

Plaintiff counsel: C. Wilson DuBose, Madison, Ga.