Melo-Cordero v. Shaddai Transport LLC
- Lewis Kaplan
- 1:21-cv-04837
- U.S. District Court · Southern District of New York
- 3
In Melo-Cordero v. Shaddai Transport, Judge Kaplan remanded the action after declining supplemental jurisdiction over Robinson’s cross-claims.
Windell I. Robinson’s cross-claims against the other defendants were not retained in federal court; the action was remanded to state court and the federal case was closed.
What happened
In Melo-Cordero v. Shaddai Transport LLC, plaintiff Francisco Melo-Cordero reported that he had settled his entire case against all defendants, and the court dismissed the case. Defendant Windell I. Robinson then told the court that he intended to continue pursuing cross-claims against the other defendants.
The court found that Robinson’s cross-claims did not meet the requirements for diversity jurisdiction. Robinson was alleged to reside in New Jersey, while two companies involved in the cross-claims were also described as having New Jersey citizenship. The cross-claims also did not allege that more than $75,000 was at stake.
The court declined to keep the state-law cross-claims under its related-claim jurisdiction, concluding that the relevant considerations favored allowing a state court to handle them. Judge Lewis A. Kaplan remanded the action to state court and directed the clerk to close the case.
The detailed version
- Melo-Cordero v. Shaddai Transport LLC · No. 1:21-cv-04837
- Lewis Kaplan
- Apr. 22, 2025
Background
Francisco Melo-Cordero brought a diversity action against Windell I. Robinson, FTVY Logistics LLC, Shaddai Transport LLC, Shaddai Transport of NJ, and Amazon Logistics, Inc. Robinson asserted a cross-claim against his co-defendants in his answer to the Second Amended Complaint.
Melo-Cordero later filed a letter stating that he had settled the entire action against all defendants. The court dismissed the case that same day. Robinson then advised the court that he intended to continue pursuing his cross-claim against the other defendants.
Jurisdiction
The court concluded that Robinson’s cross-claim did not satisfy the requirements for diversity jurisdiction. Robinson’s answer stated that he resided in New Jersey. The Second Amended Complaint described Shaddai Transport of NJ as a New Jersey limited liability corporation whose member was a New Jersey citizen, and described FTVY Logistics LLC as a New Jersey limited liability corporation whose member was a New Jersey citizen. Based on those allegations, the court found no complete diversity among the parties to the cross-claim.
The cross-claim also did not allege that the amount in controversy exceeded $75,000, another requirement for diversity jurisdiction.
Supplemental Jurisdiction and Disposition
Supplemental jurisdiction is the court’s authority to hear related claims that do not independently satisfy federal jurisdiction requirements. The court explained that, after the jurisdiction-conferring claims had been disposed of, deciding whether to retain related claims depended on judicial economy, convenience, and fairness.
The court declined to exercise supplemental jurisdiction over Robinson’s cross-claims. It reasoned that the dispute was governed by state law, that retaining it would not advance a substantial federal policy, that the court’s investment of time and resources was not extensive enough to justify keeping the matter, and that the discovery could be used in state court. The court also noted a preference for dismissing supplemental claims when the federal claims are resolved before trial.
The court remanded the action to state court and directed the clerk to close the case.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.