Houser Holdings CA, LLC v. Old Republic National Title Insurance Company
- Jacquelyn Corley
- 3:24-cv-09508
- U.S. District Court · Northern District of California
- 2
In Houser Holdings v. Old Republic, Judge Corley ordered plaintiff to provide its LLC members’ citizenship to address incomplete diversity-jurisdiction allegations.
Houser Holdings CA, LLC must provide information about the citizenship of each of its members so the court can evaluate diversity jurisdiction.
What happened
Houser Holdings CA, LLC sued Old Republic National Title Insurance Company over insurance coverage and claimed the parties were citizens of different states, giving the federal court jurisdiction.
The court explained that an LLC’s citizenship depends on the citizenship of each member, not its state of formation or principal place of business. The complaint therefore did not properly establish diversity jurisdiction, and no other federal jurisdictional basis was clear.
Judge Jacquelyn Corley ordered Houser Holdings to file supplemental information identifying the citizenship of each LLC member by February 13, 2025. The order did not decide the insurance claims.
The detailed version
- Houser Holdings CA, LLC v. Old Republic National Title Insurance Company · No. 3:24-cv-09508
- Jacquelyn Corley
- Jan. 28, 2025
Background
Houser Holdings CA, LLC brought insurance coverage claims against Old Republic National Title Insurance Company. The complaint invoked diversity jurisdiction under 28 U.S.C. § 1332, alleging that Houser Holdings was a California limited liability company with its principal place of business in Willits, California, and that Old Republic was a Florida corporation with its principal place of business in Tampa, Florida.
Jurisdictional issue
The court explained that an LLC is a citizen of every state in which its members are citizens. As a result, the LLC’s state of formation and principal place of business did not establish its citizenship for diversity-jurisdiction purposes. The complaint did not identify the citizenship of each member, so it did not properly allege complete diversity. The court also stated that no other basis for federal subject-matter jurisdiction was clear from the complaint.
Order
The court ordered Houser Holdings to make a supplemental filing setting forth the citizenship of each member of the LLC by February 13, 2025. The opinion did not dismiss the case or decide the insurance coverage claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.