Caterpillar, Inc. v. Lewis
Yeazell, p. 252-256
Facts: Lewis sued Caterpillar in state court along with Whayne, a local company. The insurance carrier for Lewis’s employer became a plaintiff to try to subrogate Caterpillar and Whayne for workers’ comp. Lewis settled with Whayne.
Procedural Posture: Caterpillar moved for removal upon the settlement between Lewis and Whayne, saying that the case now had complete diversity between the parties. Lewis argued that Whayne was still a defendant because they were still getting sued by the insurance company. The district court denied Lewis’s objection to removal. Liberty Mutual and Whayne settled before trial. Caterpillar then won at trial.
Issue: If there isn’t complete diversity between the parties at the time of removal and the federal courts hear the case anyway, are their subsequent rulings still good given that there was complete diversity of the parties at the time of trial?
Rule: Once a case comes to trial in federal court, general efficiency considerations will trump fairness considerations in specific cases.