Melrose North LLC v. Falls Lake National Insurance Company
- Rochon
- 1:25-cv-05742
- U.S. District Court · Southern District of New York
- 2
In Melrose North LLC v. Falls Lake National Insurance Company, Judge Rochon dismissed the complaint for inadequately pleaded diversity jurisdiction.
The five plaintiffs and Falls Lake National Insurance Company; the complaint was dismissed because the plaintiffs did not adequately plead the citizenship information needed for diversity jurisdiction.
What happened
Melrose North LLC v. Falls Lake National Insurance Company involves an insurance dispute brought by five plaintiffs against Falls Lake National Insurance Company. The plaintiffs relied on diversity of citizenship to establish federal jurisdiction.
The complaint identified citizenship information for some parties but did not state the citizenship of every member of the two plaintiff limited liability companies or the partners of the plaintiff limited partnership. The court ordered the plaintiffs to amend the complaint by July 22, 2025, and warned that failure to truthfully plead complete diversity would result in dismissal.
The plaintiffs did not amend the complaint or contact the court by the deadline. Judge Jennifer L. Rochon dismissed the complaint for lack of subject matter jurisdiction.
The detailed version
- Melrose North LLC v. Falls Lake National Insurance Company · No. 1:25-cv-05742
- Rochon
- July 23, 2025
Background
Melrose North LLC, Melrose Housing Development Fund Corporation, Home Builders 1 L.P., Ace Industries NY LLC, and Federated Mutual Insurance Company sued Falls Lake National Insurance Company. The plaintiffs invoked federal jurisdiction based on diversity of citizenship, which generally requires complete diversity between the opposing sides and satisfaction of the statutory amount requirement. The opinion focuses on whether the complaint adequately pleaded the parties' citizenship.
The complaint alleged that Melrose Housing Development Fund Corporation was a New York corporation with its principal place of business in New York; Federated Mutual Insurance Company was a Minnesota company with its principal place of business in Minnesota; Melrose North LLC and Ace Industries LLC were organized under New York law and had their principal places of business in New York; Home Builders 1 L.P. was organized under New York law and had its principal place of business in New York; and Falls Lake National Insurance Company was incorporated in Ohio and had its principal place of business in North Carolina.
Jurisdictional Deficiencies
The court held that the complaint did not affirmatively allege the citizenship of each member of Melrose North LLC and Ace Industries LLC. It also did not allege the citizenship of Home Builders 1 L.P.'s partners, including each general and limited partner. Because those allegations were required to establish complete diversity, the court previously ordered the plaintiffs to amend their complaint by July 22, 2025.
The court warned that if the plaintiffs could not truthfully allege complete diversity by that date, the complaint would be dismissed for lack of subject matter jurisdiction without further notice. The deadline passed without an amended complaint or other communication from the plaintiffs.
Ruling
Judge Jennifer L. Rochon dismissed the complaint for lack of subject matter jurisdiction. The opinion does not state that the dismissal was with prejudice or without prejudice. The order addresses the adequacy of the jurisdictional allegations and does not decide the underlying insurance dispute.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.