Raynaud v. Mulligan Security, LLC
- Rochon
- 1:25-cv-01782
- U.S. District Court · Southern District of New York
- 2
Raynaud v. Mulligan Security, LLC: Judge Rochon dismissed the amended complaint without prejudice because it did not establish federal diversity jurisdiction.
The dismissal affects La’Rue Raynaud and Emmanuel “Tahon” Ramirez’s amended complaint against Mulligan Security LLC. The court did not reach the merits of their underlying claims.
What happened
In Raynaud v. Mulligan Security, LLC, La’Rue Raynaud and Emmanuel “Tahon” Ramirez sued Mulligan Security LLC in federal court, relying on diversity of citizenship. They alleged that they were New York citizens and that Mulligan Security LLC was incorporated in Delaware.
The court had ordered the plaintiffs to identify the citizenship of every member of the LLC. Instead, their amended complaint said only that Mulligan Security LLC was incorporated in Delaware and therefore was a Delaware citizen. The court explained that an LLC’s citizenship depends on the citizenship of its members, not merely its state of incorporation.
Judge Jennifer L. Rochon dismissed the amended complaint without prejudice for lack of subject matter jurisdiction. This means the dismissal did not bar the plaintiffs from bringing the matter again, but the court did not proceed to the underlying claims.
The detailed version
- Raynaud v. Mulligan Security, LLC · No. 1:25-cv-01782
- Rochon
- Mar. 24, 2025
Background
La’Rue Raynaud and Emmanuel “Tahon” Ramirez sued Mulligan Security LLC. They invoked federal diversity jurisdiction under 28 U.S.C. § 1332, alleging that they were citizens of New York and that Mulligan Security LLC was a Delaware foreign limited liability company.
The court previously directed the plaintiffs to amend their complaint to allege the citizenship of each person or entity that was a member of Mulligan Security LLC. The court warned that the complaint would be dismissed for lack of subject matter jurisdiction if the plaintiffs could not truthfully allege complete diversity of citizenship.
Issue
The amended complaint stated only that Mulligan Security LLC was incorporated in Delaware and was therefore a citizen of Delaware. The court explained that a limited liability company is considered a citizen of every state in which its members are citizens. Alleging the LLC’s place of incorporation was therefore insufficient to establish the court’s diversity jurisdiction.
Ruling
The court dismissed the Amended Complaint without prejudice for lack of subject matter jurisdiction. The court did not decide the underlying claims. Judge Jennifer L. Rochon issued the order on March 24, 2025.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.