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S.D.N.Y.Procedural orderFiled Sept. 30, 2025

Colliton v. Global

Judge
Laura Swain
Docket
1:25-cv-03534
Court
U.S. District Court · Southern District of New York
Pages
7
Civil ProcedurePro Se
In one sentence

Colliton v. BM Global: Judge Stanton dismissed the case for lack of jurisdiction, allowing Colliton 30 days to replead.

Who this affects

James Colliton’s federal lawsuit against BM Global was dismissed for lack of subject matter jurisdiction, but he was given 30 days to replead. BM Global remains the defendant in the case.

What happened

In James Colliton v. BM Global, James Colliton alleged that BM Global interfered with his business relationship with HR Penn ADW and disclosed his personal information after a dispute involving MGM Empire. He sought money damages and relied on the court’s power to hear disputes between citizens of different states.

The court found that the complaint did not provide facts showing that more than $75,000 was at stake, as required for this type of federal jurisdiction. It dismissed the action for lack of subject matter jurisdiction but gave Colliton 30 days to file an amended complaint addressing the defects, including explaining what BM Global did, when and where it happened, why he was entitled to relief, and BM Global’s full address if available.

Judge Louis L. Stanton issued the order on September 30, 2025. The court stated that if Colliton does not amend within 30 days, the Clerk will enter judgment, and it held the matter open on the docket until further order.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Colliton v. Global · No. 1:25-cv-03534
Judge
Laura Swain
Date
Sept. 30, 2025

Background

James Colliton, representing himself, sued BM Global and sought permission to proceed without paying court fees in advance. The court had previously granted that request. Colliton invoked diversity jurisdiction, which allows a federal court to hear certain state-law disputes involving citizens of different states when more than $75,000 is at stake.

According to the complaint, Colliton had a dispute with MGM Empire, and BM Global employees communicated with him on MGM’s behalf. He later alleged that BM Global told him that management of HR Penn ADW had decided to stop doing business with him and not pay him. Colliton claimed that BM Global interfered with his relationship with HR, disclosed his personal information to MGM without authorization, caused his HR account to be frozen, and prevented him from receiving funds. He requested an amount determined by a jury.

Court’s Analysis

The court explained that diversity jurisdiction requires the plaintiff and defendant to be citizens of different states and requires a reasonable probability that the amount in dispute exceeds $75,000. Colliton alleged that he was a New York citizen and that BM Global was a Connecticut citizen, although he did not provide BM Global’s full address. The court said that, even assuming the parties were citizens of different states, the complaint contained no facts suggesting that the amount in controversy exceeded $75,000.

Because the court lacked subject matter jurisdiction, it did not decide whether BM Global actually interfered with a contract, unlawfully disclosed information, or otherwise violated Colliton’s rights. The court also stated that Colliton’s amended complaint must provide a short and plain statement of the relevant facts and explain how BM Global violated his rights, when and where the violations occurred, and why he was entitled to relief.

Disposition

The court dismissed the action for lack of subject matter jurisdiction and granted Colliton 30 days’ leave to replead. If he does not file an amended complaint within that period, the Clerk of Court will enter judgment without further order. The court directed the Clerk to hold the matter open until further order and stated that the order does not limit Colliton’s right to seek any relief available in state court.

The authoritative version

Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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