Arikapudi v. Wipro VLSI Design Services, LLC
- Nathanael Cousins
- 5:23-cv-02453
- U.S. District Court · Northern District of California
- 3
In Arikapudi v. Wipro VLSI, Judge Cousins ordered clarification of LLC citizenship supporting federal jurisdiction, warning of remand.
Ravindran Arikapudi, Wipro VLSI Design Services, LLC, Wipro IT Services, LLC, and Wipro, LLC; the order concerns whether the federal court has jurisdiction to hear the removed employment case.
What happened
Arikapudi v. Wipro VLSI Design Services, LLC involves employment-related claims that Ravindran Arikapudi filed in California state court before Wipro VLSI removed the case to federal court.
The court found that Wipro VLSI had not adequately shown the citizenship of its corporate members. Because a limited liability company’s citizenship depends on its members, the court could not determine whether the parties were citizens of different states or whether federal jurisdiction existed.
Judge Nathanael M. Cousins ordered a written citizenship statement by June 19, 2023, but the opinion contains conflicting language about whether Wipro VLSI or Arikapudi must file it. The court stated that the case would be sent back to state court if Wipro VLSI failed to comply.
The detailed version
- Arikapudi v. Wipro VLSI Design Services, LLC · No. 5:23-cv-02453
- Nathanael Cousins
- June 6, 2023
Background
Ravindran Arikapudi sued Wipro VLSI Design Services, LLC and unnamed defendants in California state court, asserting employment-related claims. Wipro VLSI removed the action to federal court. The removal papers stated that Wipro VLSI’s sole member was Wipro IT Services, LLC; Wipro IT Services, LLC’s sole member was Wipro, LLC; and Wipro, LLC’s sole member was Wipro Limited. The papers identified Wipro Limited as incorporated and having its principal place of business in India.
Jurisdictional issue
The court explained that it must independently confirm subject-matter jurisdiction, meaning the court’s legal authority to hear the case. Wipro relied on diversity jurisdiction, which generally requires more than $75,000 in controversy and opposing citizenship between the parties. For a limited liability company, citizenship is based on the citizenship of every member, including the members of any LLC members further up the ownership chain.
The court concluded that identifying Wipro Limited’s citizenship did not establish the citizenship of Wipro VLSI, Wipro IT Services, LLC, or Wipro, LLC. Because the removal papers did not provide the citizenship of those entities, the court could not determine whether complete diversity existed. It therefore found that Wipro VLSI had not carried its burden of showing that removal was proper.
Order
The opinion first states that the court ordered Wipro VLSI to file a statement clarifying the citizenship of its corporate members. Later, however, the order states that the court ordered Arikapudi to file a written statement detailing the citizenship of Wipro VLSI, Wipro IT Services, LLC, and Wipro, LLC by June 19, 2023. The text does not resolve this inconsistency. It states that if Wipro VLSI failed to comply, the case would be remanded, meaning returned, to state court for lack of subject-matter jurisdiction. The order did not decide the underlying employment claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.