Washington Mills Apartments II Limited Partnership v. Ironshore Insurance…
Washington Mills Apartments II Limited Partnership v. Ironshore Insurance Services, LLC
- Paul Engelmayer
- 1:20-cv-04773
- U.S. District Court · Southern District of New York
- 2
In Washington Mills Apartments II v. Ironshore Insurance Services, Judge Engelmayer ordered citizenship details before proceeding on diversity jurisdiction.
The plaintiff, the defendant, and their counsel were affected because the court required information about the citizenship of the plaintiff’s partners and the defendant’s members before the case could proceed.
What happened
Washington Mills Apartments II Limited Partnership v. Ironshore Insurance Services, LLC concerned whether the complaint adequately showed that the federal court had diversity jurisdiction, which is based on the parties’ citizenship.
The plaintiff identified itself as a Massachusetts limited partnership and the defendant as a New York limited liability company. But the complaint did not identify the citizenship of the partnership’s partners or the company’s members, which the court said was necessary to determine jurisdiction.
Judge Paul A. Engelmayer ordered the lawyers to file a letter by July 10, 2020, listing those citizenship details. The order did not address the underlying dispute.
The detailed version
- Washington Mills Apartments II Limited Partnership v. Ironshore Insurance… · No. 1:20-cv-04773
- Paul Engelmayer
- June 24, 2020
Background
Washington Mills Apartments II Limited Partnership filed the complaint on June 23, 2020. The complaint identified diversity of citizenship as the sole basis for federal subject-matter jurisdiction.
The court observed that the plaintiff is a limited partnership and the defendant is a limited liability company. For a limited partnership, citizenship depends on the citizenship of each general and limited partner. For a limited liability company, citizenship depends on the citizenship of each member.
Jurisdictional issue
The complaint alleged that the plaintiff was organized under Massachusetts law, but it did not allege the citizenship of the plaintiff’s general and limited partners. It also alleged that the defendant was organized under New York law and had its principal place of business in New York, but it did not allege the citizenship of the defendant’s members.
Because the court could not determine from the complaint whether diversity jurisdiction existed, it stated that it could not proceed to the merits before resolving that issue.
Order
The court directed counsel to file a letter by July 10, 2020, listing the citizenship of each of the plaintiff’s general and limited partners and each of the defendant’s members. The opinion did not decide the underlying dispute or state that any claim or motion was dismissed or granted.
Disposition
The court issued an order requiring additional jurisdictional information. The classification is procedural because the order addressed whether the court had jurisdiction and did not reach the merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.