Reported / Citable
Background
Charles Jackson filed suit in Texas state court arising from a February 19, 2025 multi-vehicle truck accident in Colorado. Jackson alleged that Javier Feliz, driving a tractor trailer for Covenant Transport, negligently crossed the center line and collided with Adam Scott’s tractor trailer. That collision diverted Feliz’s vehicle into a head-on collision with Jackson’s truck. Jackson sued Feliz and Covenant Transport for negligence and vicarious liability, and also sued Scott for failing to maintain a proper lookout and take evasive action to avoid the initial collision.
In the original petition, Jackson alleged that both he and Scott were Texas citizens, which destroyed diversity jurisdiction. The defendants removed the case to federal court, claiming complete diversity existed because Scott was improperly joined solely to defeat federal jurisdiction. The defendants argued the police report established no reasonable basis to predict Jackson could recover against Scott.
The Court’s Holding
The court remanded the case to state court, holding that Scott was properly joined and diversity jurisdiction was therefore incomplete. Although the defendants established the amount in controversy exceeded $75,000, they failed to meet the heavy burden of proving improper joinder. Under the Fifth Circuit’s strict standard, a defendant is improperly joined only if there is no possibility of recovery against the in-state defendant—a burden the court emphasized must be resolved against the removing defendants.
The court applied a Rule 12(b)(6) analysis to Jackson’s allegations against Scott. Jackson pleaded that Scott owed a duty to maintain a proper lookout and take reasonable evasive action to avoid collision, and that Scott breached these duties. Under Texas law governing vehicle operation, these duties are recognized and Scott’s alleged failure to perform them states a plausible claim for negligence. The court rejected the defendants’ reliance on the police report’s opinion that Scott did not contribute to the accident, finding that this single document was insufficient to overcome Jackson’s well-pleaded allegations, which must be accepted as true at the removal stage.
Key Takeaways
- The improper joinder doctrine places a heavy burden on defendants seeking to prove an in-state defendant was joined solely to defeat diversity—doubts are resolved in favor of remand.
- At the removal stage, courts must accept the plaintiff’s well-pleaded factual allegations as true and indulge every reasonable inference in the plaintiff’s favor.
- A single document like a police report, even if it contradicts the plaintiff’s allegations, does not establish that a claim is implausible or that recovery is impossible.
- Defendants cannot use improper joinder doctrine to attack the merits of a claim by re-litigating factual disputes that are better resolved at summary judgment or trial.
Why It Matters
This decision reinforces that the improper joinder doctrine is narrowly construed and places substantial obstacles in the path of defendants seeking to remove cases by arguing a state-citizen defendant was fraudulently joined. Plaintiffs retain significant pleading flexibility in trucking and motor vehicle accident cases to allege duty breaches based on failure to maintain lookout and take evasive action, and courts will not dismiss such claims at the removal stage merely because a police report or other external document contradicts them.
For defendants, the ruling underscores that establishing improper joinder requires clear proof of no reasonable basis for recovery, not speculation or reliance on evidence that appears in supporting documents but conflicts with the complaint’s allegations. The decision may have practical consequences for removal strategy in multiparty accident cases where in-state defendants are involved.