Jailineli LTD. v. Prodigy Network, LLC
- Edgardo Ramos
- 1:20-cv-02906
- U.S. District Court · Southern District of New York
- 2
In Jailineli v. Prodigy, Judge Ramos ordered plaintiffs to establish federal jurisdiction because citizenship details could defeat diversity jurisdiction.
The plaintiffs must provide a declaration establishing the basis for federal subject-matter jurisdiction by May 1, 2020. The order also raises potential jurisdictional issues concerning the citizenship of a plaintiff limited partnership’s partners and a defendant limited liability company’s members.
What happened
Jailineli LTD. v. Prodigy Network, LLC involves plaintiffs who sued defendants in federal court based on diversity jurisdiction.
The court explained that diversity jurisdiction requires complete diversity between the parties. It identified possible citizenship issues involving the plaintiff limited partnership’s partners and the defendant limited liability company’s members.
Judge Edgardo Ramos ordered the plaintiffs to submit a declaration establishing the basis for subject-matter jurisdiction by May 1, 2020. The order did not decide the merits of the dispute.
The detailed version
- Jailineli LTD. v. Prodigy Network, LLC · No. 1:20-cv-02906
- Edgardo Ramos
- Apr. 10, 2020
Background
The plaintiffs are Jailineli LTD., Raquette View Limited, Liquid, LP, Benjamin Beja Lezama, and Mariana Pinto Escandon. The defendants are Prodigy Network, LLC, 1400 N Orleans Newco, Inc., Prodigy Shorewood Domestic Feeder Rep Fund, LLC, and Rodrigo Niño.
The parties invoked diversity jurisdiction under 28 U.S.C. § 1332. The court explained that this requires complete diversity, meaning that opposing parties cannot share the relevant citizenship that would defeat federal jurisdiction.
Jurisdictional concerns
The opinion states that the plaintiffs include two foreign corporations, two foreign individuals, and a limited partnership with no partners who are citizens of New York. The defendants include two Delaware corporations with principal places of business in New York, an individual domiciled in New York, and a limited liability company with no Mexican members.
The court identified two possible problems. First, if Liquid, LP has a partner who is a Delaware citizen, diversity would be destroyed because Delaware citizens would be on both sides. Second, if any member of the defendant limited liability company is a citizen of a foreign country, foreign citizens would be on both sides of the dispute.
Order
The court ordered the plaintiffs to submit a declaration establishing a basis for subject-matter jurisdiction by May 1, 2020. This was a jurisdictional order; the court did not decide the underlying dispute.
Judge Edgardo Ramos signed the order on April 9, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.