In Re Laundress Marketing and Product Liability Litigation

Background

The litigation includes several remaining member cases. In four of them—Macha v. The Laundress, LLC, et al., No. 24-CV-2108; McGowan v. The Laundress, LLC, No. 24-CV-8018; Safran v. The Laundress, LLC, et al., No. 24-CV-865; and Wyatt v. The Laundress, LLC, et al., No. 24-CV-7083—the plaintiffs invoked federal subject-matter jurisdiction based on diversity of citizenship under 28 U.S.C. § 1332.

Jurisdiction Issue

The Court stated that the complaints did not properly allege complete diversity. Complete diversity generally requires the parties on opposite sides of a case to be citizens of different states. For jurisdictional purposes, a limited liability company is treated as a citizen of every state where each of its members is a citizen. Therefore, a complaint relying on diversity jurisdiction must identify the citizenship of individual members and, for corporate members, their state of incorporation and principal place of business. The complaints at issue did not provide the required information, including information about members that might themselves be limited liability companies.

Order

Judge Jesse M. Furman ordered the parties in all four member cases to file a single joint letter no later than May 19, 2025. The letter must address whether the Court has subject-matter jurisdiction and propose next steps. The order did not determine whether jurisdiction exists and did not state that any case was dismissed.