Issue: What factors determine whether a Minnesota federal district court would be a proper venue for a lawsuit?
|Area of Law:||Litigation & Procedure|
|Keywords:||Federal diversity-jurisdiction; Venue for the case; Substantial connection|
|Cited Cases:||365 S.E.2d 442; 617 F. Supp. 190; 446 F.2d 225; 722 F. Supp. 1020; 505 F. Supp. 2d 573; 952 F. Supp. 1335|
|Cited Statutes:||28 U.S.C. § 1332(a)(1), § 1391(a), § 1391(c); Minn. Stat. § 542.06|
The first step in establishing whether venue would be proper in the Minnesota federal district court is to determine that the court has jurisdiction to hear the case. The federal diversity-jurisdiction statute, 28 U.S.C. § 1332(a)(1) (2010), provides that “[t]he district courts shall have original jurisdiction of all civil actions where the matter in controversy exceeds the sum or value of $75,000, exclusive of interest and costs, and is between (1) citizens of different States[.]” Importantly, “it is well-settled that two or more claims asserted by a single plaintiff against a single defendant may be aggregated for purposes of determining whether the jurisdictional amount requirement has been met.” 14C Charles A. Wright et al., Federal Practice & Procedure—Jurisdiction §§ 3725, 3725.3 (2011); accord Lynch v. Porter, 446 F.2d 225, 228 (8th Cir. 1971) (similarly stating that “[i]t is a well settled rule that once diversity jurisdiction is properly invoked, a single plaintiff may properly aggregate all of the claims which he has against the defendants to satisfy the jurisdictional amount.”) (citing cases).
Once jurisdiction is established, the appropriate venue for the case may next be considered. The federal venue statute provides:
A civil action wherein jurisdiction is founded only on diversity of citizenship may, except as otherwise provided by law, be brought only in
(1) a judicial district where any defendant resides, if all defendants reside in the same State,