2. The party invoking diversity jurisdiction has the burden of showing that the amountin-

controversy requirement is met. In meeting this burden, the Supreme Court has established a rule that “the sum claimed by the plaintiff controls if the claim is apparently made in good faith. It must appear to a legal certainty that the claim is really for less than the jurisdictional amount to justify dismissal.” ST. PAUL MERCURY INDEMNITY CO. v.

RED CAB CO., 303 U.S. 283, 288–89, 58 S.Ct. 586, 590, 82 L.Ed. 845, 848 (1938) (footnotes omitted). Under what circumstances could a court find to a legal certainty that a party’s claim does not meet the amount-in-controversy requirement? The circuits are divided as to whether their review is limited to plaintiff’s good faith allegation or whether the court may look beyond the pleadings in determining whether the requirement is met. See Hurstak, Note The Uncertain Status of the Legal Certainty Test: The Need for Consistency Among Federal Courts When Determining the Amount-in-Controversy, 14 Suffolk J. Trial & App. Advoc. 78 (2009).