ANDERS v. JUUL LABS, INC.
- William Orrick
- 3:20-cv-06653
- U.S. District Court · Northern District of California
- 3
In Anders v. Juul Labs, Judge Tanya Walton Pratt ordered a citizenship statement because the complaint did not adequately establish diversity jurisdiction.
Thomas Anders must provide additional information about every party’s citizenship so the court can determine whether diversity jurisdiction exists; the defendants and the case’s continued consideration are also affected.
What happened
In Anders v. Juul Labs, Inc., Thomas Anders sued Juul Labs, Inc., and other defendants, alleging that federal jurisdiction existed because the parties were citizens of different states.
The court found that the complaint often alleged where parties lived or operated, rather than their citizenship. It also said the complaint did not identify the members and citizenship of certain limited liability companies or provide jurisdictional information for two other defendants.
Judge Tanya Walton Pratt ordered Anders to file a supplemental jurisdictional statement identifying each party’s citizenship within 14 days. The order did not decide the underlying claims.
The detailed version
- ANDERS v. JUUL LABS, INC. · No. 3:20-cv-06653
- William Orrick
- Sept. 14, 2020
Background
Thomas Anders’s complaint named Juul Labs, Inc., doing business as PAX Labs, Inc. and Ploom Inc., along with Altria Group, Inc., Altria Group Distribution Company, James Monsees, Adam Bowen, Hoyoung Huh, Riaz Valani, Nicholas Pritzker, Mother Murphy’s Labs, Inc., Alternative Ingredients, Inc., Tobacco Technology, Inc., Eliquitech, Inc., McLane Company, Inc., Eby-Brown Company, LLC, Core-Mark Holding Company, Inc., Philip Morris USA, Inc., Altria Enterprises LLC, and Altria Client Services LLC. The complaint asserted federal subject-matter jurisdiction based on diversity of citizenship.
Jurisdictional Deficiencies
The court explained that diversity jurisdiction depends on citizenship, not residence. For corporations, the complaint must identify both the state of incorporation and the state of the principal place of business. For a limited liability company, the jurisdictional statement must identify the citizenship of each member and, when applicable, the citizenship of members of those members.
The complaint described Thomas Anders as a resident of Indiana and described several individual defendants as residents of, or based in, the San Francisco Bay Area, San Francisco, or Silicon Valley. The court found those residence allegations insufficient to establish citizenship. It also found that the allegations concerning Altria Enterprises LLC and Eby-Brown Company, LLC did not identify their members and citizenship. In addition, the complaint contained no jurisdictional allegations concerning Altria Group Distribution Company or Altria Client Services LLC.
Order
Because Anders was the party asking the court to exercise diversity jurisdiction, the court ordered him to file a supplemental jurisdictional statement establishing the citizenship of each party. The statement was due 14 days from the date of the order. The court did not rule on the merits of the claims or dismiss the case in this entry. Tanya Walton Pratt signed the order as judge of the United States District Court for the Southern District of Indiana.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.