The Beaumont Court of Appeals has held that the minimum amount in controversy necessary to invoke a district court’s jurisdiction is $201.00.
In Acreman v. Sharp, the trial court dismissed Plaintiff Acreman’s claims against an employee of the Texas Department of Criminal Justice because Acreman’s petition asserted that the value of the property he was complaining of was $400.00. The trial court concluded that the minimum amount in controversy to invoke a district court’s jurisdiction must exceed $500.00. Acreman appealed.
Prior to 1985, the state constitution established a minimum amount in controversy for district court jurisdiction at $500.00. Voters amended the constitution in 1985 to delete reference to any amount and the constitution now allows the legislature to set the jurisdictional limits. No minimum limit is now provided for the district courts, however, the state constitution, Article V, Section 19 gives exclusive jurisdiction to justice of the peace courts for claims amounting to $200.00 or less.
At present, there appears to be a split in authority. Three courts of appeals–the Houston First District, Texarkana, and Amarillo–have held that the minimum amount in controversy to invoke district court jurisdiction is $201.00. Beaumont has joined this group. Three courts of appeals–Tyler, Corpus Christi, and Waco–have held that the minimum amount in controversy is $500.00. In view of the conflict, this issue seems ripe for the Texas Supreme Court to resolve the conflict.
The court of appeals’ opinion is available here.