Lewandowski v. Chipotle Mexican Grill, Inc.
- Valerie Caproni
- 1:20-cv-00948
- U.S. District Court · Southern District of New York
- 1
In Lewandowski v. Chipotle, Judge Caproni ordered Plaintiff to explain why the case should not be dismissed without prejudice for lack of subject-matter jurisdiction.
Camille Lewandowski and Chipotle Mexican Grill, Inc.; Plaintiff was required to explain whether federal subject-matter jurisdiction existed.
What happened
In Lewandowski v. Chipotle Mexican Grill, Inc., the complaint alleged that Camille Lewandowski was a New York resident and that Chipotle was formed under New York law. The case invoked federal diversity jurisdiction, which generally requires the opposing parties to be citizens of different states.
The court explained that Plaintiff had to show that federal jurisdiction existed, including complete diversity. Because the complaint appeared to identify both parties as connected to New York, the court questioned whether diversity jurisdiction was present.
Judge Valerie Caproni did not dismiss the case at this stage. She ordered Plaintiff to file a letter by February 12, 2020, explaining why the case should not be dismissed without prejudice for lack of federal subject-matter jurisdiction.
The detailed version
- Lewandowski v. Chipotle Mexican Grill, Inc. · No. 1:20-cv-00948
- Valerie Caproni
- Feb. 5, 2020
Background
Camille Lewandowski sued Chipotle Mexican Grill, Inc. The complaint invoked federal diversity jurisdiction. Diversity jurisdiction requires, among other things, complete diversity between the opposing parties.
The complaint stated that Lewandowski “was and still is a resident of New York.” It also stated that Chipotle “was and still is a corporation or a body corporate formed and existing in accordance with the laws of the State of New York.” The court noted that Plaintiff, as the party invoking federal jurisdiction, had the burden of showing that subject-matter jurisdiction existed.
Order
Federal Rule of Civil Procedure 12(h)(3) requires dismissal without prejudice if the court determines that it lacks subject-matter jurisdiction. The court therefore ordered Plaintiff to file a letter by February 12, 2020, showing why the case should not be dismissed without prejudice for lack of federal subject-matter jurisdiction.
The opinion is a show-cause order, not a dismissal. It does not state that the case was dismissed or decide the underlying dispute.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.