Blattner Energy, Inc. v. Jones

Background

Blattner Energy, Inc. sued Stephen D. Jones and Anthony Vorderbruggen in Minnesota District Court, Seventh Judicial District (Stearns County). Blattner alleged that the defendants misappropriated trade secrets and confidential information, breached their duties of loyalty, interfered with prospective economic advantage, and conspired. Blattner also sought a declaratory judgment against Jones.

The defendants removed the case to the United States District Court for the District of Minnesota based on diversity jurisdiction, which generally requires more than $75,000 in controversy and complete citizenship diversity between the opposing sides. The parties agreed that the amount-in-controversy requirement was met and that the case did not present a federal question. The dispute concerned whether Jones and Vorderbruggen were citizens of Minnesota or Colorado when the state lawsuit was filed and when the case was removed.

The complaint and caption identified Jones’s middle initial as “P,” but the court stated that Stephen D. Jones was the proper defendant and had been properly served. Blattner alleged that Jones and Vorderbruggen had worked for Blattner before leaving to work for Primoris Renewable Energy. Jones argued that he had moved to Colorado, signed a Colorado lease, and started working at Primoris’s Denver office before the lawsuit was filed.

Jurisdictional analysis

For diversity jurisdiction, citizenship is based on domicile rather than merely residence. To establish a change of domicile, a person must be physically present in the new state and intend to make it a home indefinitely. Courts may consider objective facts such as declarations, voting and civil-rights activity, taxes, licenses, employment, medical treatment, and property ownership. The relevant facts are those existing when the lawsuit was filed; later changes do not establish jurisdiction at that time.

The court found that the evidence supported Minnesota as Jones’s domicile on September 20, 2019, when Blattner filed the state-court complaint. Jones had physical connections to both states, but the court considered his Minnesota residence, Minnesota driver’s license, Minnesota vehicle registrations, Minnesota taxes, medical treatment in Minnesota, and employment with a company that also had a Minnesota office. The court also noted discrepancies between Jones’s declaration and documents concerning his travel and medical appointment.

The facts supporting Colorado were Jones’s apartment lease and employment with Primoris. The court concluded that those facts did not overcome the presumption that his former Minnesota domicile continued. Jones had the burden of proving that he had changed his domicile, and the court held that he did not meet that burden. At minimum, the court found doubts about his domicile, which had to be resolved in favor of remand.

Disposition

The court granted Blattner Energy’s motion to remand and remanded the matter to Minnesota District Court, Seventh Judicial District (Stearns County), for lack of subject-matter jurisdiction. The court did not address the merits of the defendants’ motion to dismiss. Judge Wilhelmina M. Wright signed the order on June 2, 2020.