Dickerson v. National Hockey League and NHL Enterprises

Background

Grace Dickerson sued the National Hockey League (NHL) and NHL Enterprises, L.P. (the LP Defendant). She invoked diversity jurisdiction, alleging that she was a citizen of California and that the defendants were citizens of New York.

Citizenship allegations

The court held that the complaint did not properly allege the citizenship of either defendant. The complaint described the NHL as a joint venture organized as an unincorporated association. For diversity purposes, an unincorporated association has the citizenship of each of its members. Although Dickerson alleged that the NHL had its principal place of business in New York and operated a league with member clubs in the United States and Canada, she did not provide the citizenship of any NHL member. The court therefore could not determine whether complete diversity existed.

The court also found that Dickerson had not properly alleged the citizenship of NHL Enterprises, L.P. A limited partnership has the citizenship of each general and limited partner. The complaint instead alleged the LP Defendant’s place of incorporation as Delaware and its principal place of business as New York, which did not establish the citizenship of its partners.

Order

Judge Jennifer L. Rochon ordered Dickerson to amend the complaint by September 15, 2025, to allege the citizenship of every person or entity comprising the NHL and the LP Defendant. The court did not dismiss the action in this order. It stated that if Dickerson failed to provide adequate citizenship allegations by the deadline, the court would dismiss the action for lack of subject-matter jurisdiction without further notice.