Jean Paul Mas, a French citizen, and Judy Mas, a United States citizen who had been domiciled in Mississippi, married in Jackson, Mississippi. Both were graduate assistants at Louisiana State University. After marrying, they returned to Baton Rouge, where they rented an apartment from Oliver Perry, a Louisiana citizen.
The Mases discovered that Perry had installed two-way mirrors in their bedroom and bathroom and had watched them during the first months of their marriage. They sued in federal district court, each alleging $100,000 in damages. A jury awarded Mr. Mas $5,000 and Mrs. Mas $15,000. Perry moved to dismiss for lack of subject-matter jurisdiction, arguing that the parties lacked diversity and that Mr. Mas had not satisfied the amount-in-controversy requirement. The district court denied the motion, and Perry appealed solely on jurisdictional grounds.
Issue #1
Whether the district court had alienage jurisdiction over Mr. Mas's claim against Perry.
Holding
Yes. Mr. Mas was a citizen of France and Perry was a citizen of Louisiana, so Mr. Mas's claim fell within the federal court's alienage jurisdiction.
Reasoning
Section 1332 permits federal jurisdiction over a civil action between a citizen of a foreign state and a citizen of a State when the statutory amount in controversy is satisfied. Mr. Mas was a French citizen, while Perry was a Louisiana citizen; thus, their citizenships supported alienage jurisdiction directly.
Issue #2
Whether Mrs. Mas was a Mississippi citizen for diversity purposes, rather than a Louisiana citizen or a citizen of France, when the complaint was filed.
Holding
Yes. Mrs. Mas remained domiciled in Mississippi and was therefore diverse from Perry, a Louisiana citizen.
Reasoning
For diversity purposes, citizenship means domicile, not mere residence. A person's domicile is her true, fixed, and permanent home—the place to which she intends to return when absent. A change in domicile requires both physical residence in a new place and an intent to remain there permanently or indefinitely. The relevant citizenship is fixed when the complaint is filed, and later moves do not defeat jurisdiction already established.
Mrs. Mas was domiciled in Mississippi when she married. Her time in Louisiana before and after the marriage did not establish a Louisiana domicile because she was there as a graduate student and teaching assistant, not with an intent to remain permanently. Although she did not plan to return to her parents' home, she had not acquired a new domicile; therefore, her Mississippi domicile continued.
The court declined to apply the traditional fiction that a wife's domicile automatically follows her husband's in these circumstances. Mr. Mas was a French citizen living in the United States as a student. Treating Mrs. Mas as automatically sharing his domicile would either make her fictionally French, even though she remained a United States citizen, or make her a Louisiana citizen aligned with Perry and thereby destroy diversity. Marriage to an alien neither stripped Mrs. Mas of her United States citizenship nor automatically changed her state domicile.
Issue #3
Whether Mr. Mas's eventual $5,000 recovery defeated the statutory amount-in-controversy requirement.
Holding
No. His good-faith allegation of $100,000 controlled unless it was legally certain that his claim could not exceed the jurisdictional threshold.
Reasoning
The amount in controversy is generally determined from the plaintiff's good-faith claim when the suit is filed. A later verdict for less than the jurisdictional amount does not itself show bad faith and does not oust federal jurisdiction.
Under the legal-certainty test, dismissal is proper only if the complaint or evidence makes clear that the claim could never have reached the required amount. After hearing the evidence, the district court concluded that the Mases had adequately established the amount in controversy, and the Fifth Circuit found no basis to disturb that conclusion.