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 LLC, Judge Kaplan declined supplemental jurisdiction and dismissed the action for lack of subject-matter jurisdiction.
Windell Robinson’s cross-claim against the other defendants was not retained in federal court, and the action was dismissed for lack of subject-matter jurisdiction. The clerk was directed to close the case.
What happened
In Melo-Cordero v. Shaddai Transport LLC, plaintiff Francisco Melo-Cordero reported that he had settled the entire action against all defendants, and the court dismissed the case. Defendant Windell Robinson then told the court he intended to continue his cross-claim against the other defendants.
The court found that Robinson’s cross-claim did not meet the requirements for federal jurisdiction based on the parties’ citizenship or the amount in dispute. The court also decided not to keep the claim under its supplemental jurisdiction because the dispute was governed by state law and the federal claims had already been resolved.
The court dismissed the action for lack of subject-matter jurisdiction and directed the clerk to close the case. Judge Lewis A. Kaplan issued the order.
The detailed version
- Melo-Cordero v. Shaddai Transport LLC · No. 1:21-cv-04837
- Lewis Kaplan
- Apr. 24, 2025
Background
Francisco Melo-Cordero brought a diversity action against Windell Robinson, FTVY Logistics LLC, Shaddai Transport LLC, Shaddai Transport of NJ, and Amazon Logistics, Inc. In his answer to the Second Amended Complaint, Robinson asserted a cross-claim against his co-defendants.
On March 14, 2025, Melo-Cordero filed a letter stating that he had settled the entire action against all defendants. The court dismissed the case that same day. On March 17, 2025, Robinson’s counsel informed the court that Robinson intended to pursue his cross-claim.
Federal jurisdiction
The court concluded that Robinson’s cross-claim did not independently satisfy the requirements for diversity jurisdiction. Robinson stated that he resided in New Jersey. The complaint described Shaddai Transport of NJ as a New Jersey limited liability corporation whose member was a New Jersey citizen, and FTVY Logistics as a New Jersey limited liability corporation whose member was a New Jersey citizen. Based on those allegations, the court found no complete diversity between the parties to the cross-claim. The cross-claim also did not allege that more than $75,000 was in dispute.
The court considered whether to exercise supplemental jurisdiction, which can allow a federal court to hear related state-law claims even when those claims do not independently qualify for federal jurisdiction. The court declined to do so. It explained that the dispute was governed by state law, retaining the claim would not advance a substantial federal policy, the court’s investment of time and resources was not extensive, and the discovery already taken could be used in state court. The court also noted the preference for dismissing supplemental claims when the federal claims are resolved before trial.
Disposition
The court declined to exercise supplemental jurisdiction over the cross-claims and ordered that the action be dismissed for lack of subject-matter jurisdiction. It directed the clerk to close the case. The opinion does not state the nature of Robinson’s cross-claim or the amount he sought.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.