MMA Fighter Management, Inc. v. Ballengee Group, LLC

Background

MMA Fighter Management, Inc. sued Ballengee Group, LLC and Lloyd Pierson. The opinion describes MMA Fighter Management as an athlete-management and services business with its principal place of business in New York. It describes Ballengee as an athlete-management business based in Texas and Pierson as a principal of Ballengee. The complaint asserted diversity of citizenship under 28 U.S.C. § 1332 as the basis for federal jurisdiction.

Jurisdictional deficiencies

For a corporation, citizenship includes the state of incorporation and the state of its principal place of business. For a limited liability company, citizenship depends on the citizenship of all its members. The court found that the complaint did not identify the states where MMA Fighter Management was incorporated. It also did not allege Pierson’s citizenship or identify Ballengee’s other members and allege their citizenship. Because these allegations were insufficient to establish complete diversity of citizenship, the court concluded that it lacked jurisdiction on the basis alleged.

Ruling

The court dismissed the complaint for lack of jurisdiction, with leave to replead an adequate basis for complete diversity of citizenship no later than 30 days from the order. Judge Alvin K. Hellerstein’s order addressed the jurisdictional allegations and did not decide the underlying dispute.