Rodriguez Diaz v. Sierra Martinez Case Brief Summary | Law Case Explained
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Rodriguez Diaz v. Sierra Martinez | 853 F.2d 1027 (1988)
Under the federal diversity statute, federal district courts have original jurisdiction over all civil actions between citizens of different states and citizens of a state and foreign nation when the amount in controversy exceeds seventy five thousand dollars. In addition, citizenship for diversity jurisdiction is usually based on what state or nation that person is domiciled in, that is, physically present with the intent to remain. In Rodriguez Diaz versus Sierra Martinez, a federal appellate court considered whether a person who was domiciled in a state at the time of filing suit was a citizen of that state for diversity jurisdiction when that person was a minor in a foreign nation.
In nineteen eighty four, seventeen year old Wilfredo Rodriguez Diaz was riding his motorcycle in Puerto Rico. While riding, Rodriguez Diaz was struck by a car driven by Marcelo Sierra Martinez. At the time, both Rodriguez Diaz and Sierra Martinez were citizens of Puerto Rico.
As a result of the collision, Rodriguez Diaz was taken to a nearby hospital and transferred to another hospital for emergency treatment. While in the second hospital, he suffered a massive bone infection and aggravated leg injury. Rodriguez Diaz was then transferred to a third hospital where he received poor treatment. Eventually, he was transferred to a New York City hospital.
Afterward, Rodriguez Diaz began living in New York and intended to remain.
Subsequently, Rodriguez Diaz sued Sierra Martinez and the two hospitals for negligence and medical malpractice in federal district court in Puerto Rico based on diversity jurisdiction.
At the time, Rodriguez Diaz was eighteen, which was the age of majority in the United States. However, in Puerto Rico, the age of majority was twenty one. Therefore, because he was still a minor in Puerto Rico, his domicile would be his parents’ domicile of Puerto Rico.
In response, the hospitals moved to dismiss for lack of diversity jurisdiction, which the district court granted. Specifically, the court held that Puerto Rico law applied, and because Rodriguez Diaz was a minor, his domicile—and therefore citizenship—was his parents’ domicile of Puerto Rico. Consequently, because all parties were citizens of Puerto Rico, there was no diversity jurisdiction. Rodriguez Diaz appealed to the United States Court of Appeals for the First Circuit.
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Rodriguez Diaz v. Sierra Martinez | 853 F.2d 1027 (1988)
Under the federal diversity statute, federal district courts have original jurisdiction over all civil actions between citizens of different states and citizens of a state and foreign nation when the amount in controversy exceeds seventy five thousand dollars. In addition, citizenship for diversity jurisdiction is usually based on what state or nation that person is domiciled in, that is, physically present with the intent to remain. In Rodriguez Diaz versus Sierra Martinez, a federal appellate court considered whether a person who was domiciled in a state at the time of filing suit was a citizen of that state for diversity jurisdiction when that person was a minor in a foreign nation.
In nineteen eighty four, seventeen year old Wilfredo Rodriguez Diaz was riding his motorcycle in Puerto Rico. While riding, Rodriguez Diaz was struck by a car driven by Marcelo Sierra Martinez. At the time, both Rodriguez Diaz and Sierra Martinez were citizens of Puerto Rico.
As a result of the collision, Rodriguez Diaz was taken to a nearby hospital and transferred to another hospital for emergency treatment. While in the second hospital, he suffered a massive bone infection and aggravated leg injury. Rodriguez Diaz was then transferred to a third hospital where he received poor treatment. Eventually, he was transferred to a New York City hospital.
Afterward, Rodriguez Diaz began living in New York and intended to remain.
Subsequently, Rodriguez Diaz sued Sierra Martinez and the two hospitals for negligence and medical malpractice in federal district court in Puerto Rico based on diversity jurisdiction.
At the time, Rodriguez Diaz was eighteen, which was the age of majority in the United States. However, in Puerto Rico, the age of majority was twenty one. Therefore, because he was still a minor in Puerto Rico, his domicile would be his parents’ domicile of Puerto Rico.
In response, the hospitals moved to dismiss for lack of diversity jurisdiction, which the district court granted. Specifically, the court held that Puerto Rico law applied, and because Rodriguez Diaz was a minor, his domicile—and therefore citizenship—was his parents’ domicile of Puerto Rico. Consequently, because all parties were citizens of Puerto Rico, there was no diversity jurisdiction. Rodriguez Diaz appealed to the United States Court of Appeals for the First Circuit.
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