Singh v. Palmetto Consulting of Columbia, LLC

Background

Pro se plaintiff Amrit Singh filed a complaint against Palmetto Consulting of Columbia, LLC, and other defendants concerning a contract dispute over ownership of an insurance company. Singh identified diversity jurisdiction as a basis for federal jurisdiction.

Jurisdictional concerns

The court explained that federal courts have limited jurisdiction. It considered three possible bases for jurisdiction:

- The United States was not a party. - The complaint appeared to assert a state-law contract dispute, so it did not present a federal question. - The complaint did not adequately establish diversity jurisdiction. Diversity jurisdiction requires complete diversity of citizenship between the plaintiff and every defendant, as well as an amount in controversy exceeding $75,000.

The court said Singh had identified the principal place of business of one defendant, American Transportation Group Insurance, Risk Retention Group, but had not provided the information needed to establish that entity’s state of incorporation and principal place of business. The complaint also did not identify the citizenship of the remaining eighteen defendants. The court further said it was unclear what relief Singh requested and that the complaint did not appear to request monetary damages exceeding $75,000.

Order

The court ordered Singh to show cause in writing by September 13, 2021, why the complaint should not be dismissed. The court stated that if Singh did not respond by that date, it would recommend dismissal of the complaint. The order itself did not dismiss the complaint. Judge Nathanael M. Cousins signed the order.