Dennis lived in California for 15 years before relocating to…
Dennis lived in California for 15 years before relocating to North Carolina a year ago to care for his ailing brother. Dennis still owns his house in California (where his adult son now resides rent-free) and maintains a California driver’s license. Dennis registered to vote in North Carolina and had his mail forwarded to his brother’s house in North Carolina. Dennis hired Pam to clean his house in California once per month. While Pam was cleaning Dennis’ house, she fell down the stairs when a stair tread broke. Pam sustained a fractured cervical spine. Pam filed a complaint in the California Superior Court against Dan for negligence. Pam’s complaint alleged as follows: “Dennis was negligent in maintaining the stairs, causing Pam’s injuries and damages.” Pam’s complaint contained a demand for relief which sought both economic and non-economic damages in the amount of $1,000,000. Pam’s process server went to Dennis’ house in California to serve the summons and complaint on Dennis. Dennis’ son answered the door and took the summons and complaint from the process server. Assume for the purposes of this question that the Federal Rules of Civil Procedure apply. Do not write on California law. Does the Federal District Court have subject matter jurisdiction over Pam’s claim? Fully discuss and explain your answer. Has Pam properly pled a claim for negligence under the Federal Rules of Civil Procedure? Fully discuss and explain your answer. Was the summons and complaint properly served on Dennis? Fully discuss and explain your answer.