James G. Smith, et al. v. State Farm General Insurance Company, et al.
- William Orrick
- 3:25-cv-08005
- U.S. District Court · Northern District of California
- 2
In James G. Smith v. State Farm, Judge Orrick remanded the case because Farmers shared California citizenship with the plaintiffs, defeating diversity jurisdiction.
The plaintiffs and defendants in the case are affected because the federal court returned the case to the Superior Court of California, County of San Francisco, for further proceedings.
What happened
James G. Smith, Erin Smith, and the Jefferson Street HOA sued State Farm General Insurance Company and others. The defendants had removed the case from California state court to federal court based on diversity jurisdiction.
The court explained that diversity jurisdiction generally requires all plaintiffs to be citizens of different states from all defendants. State Farm was domiciled in Illinois, but co-defendant Farmers Insurance Company was also domiciled in California, as were the plaintiffs.
Because the parties did not have complete diversity, the court sent the case back to the Superior Court of California, County of San Francisco. Judge Orrick issued the remand order.
The detailed version
- James G. Smith, et al. v. State Farm General Insurance Company, et al. · No. 3:25-cv-08005
- William Orrick
- Dec. 16, 2025
Background
The case had originally been removed from the Superior Court of California, County of San Francisco, to federal court based on diversity jurisdiction. State Farm General Insurance Company was identified as domiciled in Illinois. The plaintiffs—James G. Smith, Erin Smith, and the Jefferson Street HOA—were identified as California residents. During the parties’ December 16, 2025 Case Management Conference, defense counsel raised a jurisdictional problem after discovering that co-defendant Farmers Insurance Company was also domiciled in California.
Jurisdictional ruling
Under 28 U.S.C. § 1332, federal district courts may hear disputes between citizens of different states. The court explained that this requires “complete diversity,” meaning that no plaintiff may be from the same state as any defendant. Because the plaintiffs and Farmers were both California residents, the complete-diversity requirement was not satisfied.
Disposition
The court ordered that the case be REMANDED to the Superior Court of California, County of San Francisco, for all further proceedings. The opinion’s extracted signature identifies the judge as Orrick; it does not show a fuller first name.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.