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N.D. Cal.Procedural orderFiled Feb. 12, 2024

AIG Property Casualty Company v. Harken

Judge
Jacquelyn Corley
Docket
3:24-cv-00303
Court
U.S. District Court · Northern District of California
Pages
2
Civil Procedure
In one sentence

In AIG Property Casualty Company v. Harken, Judge Corley ordered AIG to show that diversity jurisdiction exists.

Who this affects

AIG Property Casualty Company, which was ordered to establish that diversity subject-matter jurisdiction exists or submit an amended complaint properly alleging its citizenship.

What happened

AIG Property Casualty Company sued Alexander Harken and others in federal court, claiming the parties were citizens of different states and that more than $75,000 was at stake.

The complaint identified the citizenship of the defendants but did not state AIG’s state of incorporation or principal place of business. Those facts are needed to determine whether the parties are completely diverse.

Judge Jacquelyn Scott Corley ordered AIG to show by February 20, 2024, that diversity jurisdiction exists. AIG may instead file an amended complaint properly stating its citizenship.

The detailed version

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

Case
AIG Property Casualty Company v. Harken · No. 3:24-cv-00303
Judge
Jacquelyn Corley
Date
Feb. 12, 2024

Background

AIG Property Casualty Company filed a complaint against Alexander Harken, Angela Aquino-Sales, James Sales, Ajay Martin, and UDR, Inc. AIG alleged that the court had diversity jurisdiction under 28 U.S.C. § 1332(a)(1), which generally requires more than $75,000 in controversy and complete diversity of citizenship between the plaintiffs and defendants.

AIG alleged that Harken, Aquino-Sales, Sales, and Martin were California citizens for diversity purposes. It alleged that UDR, Inc. was a citizen of Maryland and Colorado. But AIG did not allege its own state of incorporation or principal place of business, so the complaint did not adequately allege AIG’s citizenship.

Ruling

The court ordered AIG to show on the record, by February 20, 2024, that diversity subject-matter jurisdiction exists. The court stated that AIG may submit an amended complaint properly alleging its citizenship. The order did not decide the underlying claims.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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