Tejada v. Rodney A. Degroat and VLA Lancaster LLC
- John Cronan
- 1:25-cv-07600
- U.S. District Court · Southern District of New York
- 2
In Melanea Tejada v. Degroat, Judge Cronan ordered defendants to clarify VLA Lancaster LLC’s citizenship for diversity jurisdiction.
The defendants, particularly VLA Lancaster LLC, must provide additional information about the entity’s legal form and citizenship before the court can assess the removal jurisdiction described in the notice.
What happened
Melanea Tejada v. Rodney A. Degroat and VLA Lancaster LLC was moved from New York state court to federal court. The defendants said federal jurisdiction existed because the parties were citizens of different states.
The defendants described Tejada as a New York resident, Degroat as a Pennsylvania resident and citizen, and VLA Lancaster LLC as a corporation connected to Pennsylvania and Texas. The court explained that if VLA Lancaster is an LLC, its citizenship depends on the citizenship of its members.
Judge Cronan ordered the defendants to tell the court by September 25, 2025, whether VLA Lancaster is an LLC. If it is, they must amend the removal notice to identify the citizenship of its members.
The detailed version
- Tejada v. Rodney A. Degroat and VLA Lancaster LLC · No. 1:25-cv-07600
- John Cronan
- Sept. 15, 2025
Background
The defendants removed this case from the New York Supreme Court for Bronx County to the U.S. District Court for the Southern District of New York on September 12, 2025. Their removal notice invoked diversity jurisdiction under 28 U.S.C. § 1332(a), which generally requires the opposing parties to be citizens of different states and the required amount to be in dispute.
The notice stated that Melanea Tejada was a resident of New York, Rodney A. Degroat was a resident and citizen of Pennsylvania, and VLA Lancaster LLC was “a foreign corporation whose principal place of business is in Pennsylvania and state of incorporation is Texas.”
Court’s analysis
The court explained that a limited liability company does not have citizenship based simply on its place of incorporation or principal place of business. Instead, an LLC takes the citizenship of each of its members. A party relying on diversity jurisdiction must therefore identify the citizenship of the LLC’s individual members and, if any members are corporations, those corporations’ places of incorporation and principal places of business.
The opinion did not determine whether VLA Lancaster is an LLC or decide whether diversity jurisdiction exists. It required the defendants to clarify that issue.
Order
The court ordered the defendants to file a letter by September 25, 2025, stating whether VLA Lancaster LLC is an LLC. If it is, the defendants must amend the notice of removal to properly allege the citizenship of its members. The order did not decide the merits of Tejada’s underlying claims. Judge John P. Cronan entered the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.