Hahn v. Springer Nature Limited

Background

Chang-Gyu Hahn filed a complaint against Springer Nature Limited, Molecular Psychiatry, and Julio Licinio. The complaint asserted only state-law claims. Hahn alleged that the defendants did business in New York, that the relevant actions occurred there, and that the defendants committed tortious acts and caused injury in New York and elsewhere.

Jurisdictional issue

The court distinguished personal jurisdiction from subject-matter jurisdiction. Personal jurisdiction concerns the court’s authority over the defendants; subject-matter jurisdiction concerns the court’s authority to hear the type of case involved.

Because the complaint asserted state-law claims, the court stated that subject-matter jurisdiction, if available, would have to come from diversity jurisdiction under 28 U.S.C. § 1332. Diversity jurisdiction requires citizens of different states and an amount in controversy exceeding $75,000. The complaint did not allege where the individual parties were domiciled, where the corporate parties were incorporated, where the corporate parties maintained their principal places of business, or that the amount in controversy exceeded $75,000.

Ruling

The court concluded that the complaint did not properly plead diversity jurisdiction. Under Federal Rule of Civil Procedure 12(h)(3), a court must dismiss an action when it determines that subject-matter jurisdiction is lacking. Judge Vernon S. Broderick therefore dismissed the complaint without prejudice and with leave to replead. Hahn has 30 days to file an amended complaint that properly asserts subject-matter jurisdiction. If Hahn does not do so, the Clerk of Court is directed to terminate the action. The order did not decide the merits of Hahn’s state-law claims.