Label Health v. United American Supply
Label Health, LLC v. United American Supply, LLC, David Underwood, Arleta Taylor, and Al Taylor
- Paul Engelmayer
- 1:20-cv-05161
- U.S. District Court · Southern District of New York
- 2
In Label Health v. United American Supply, Judge Engelmayer ordered counsel to identify LLC members’ citizenship before the case could proceed.
Label Health, LLC, one defendant that is an LLC, and their counsel are affected because counsel must provide the required member-citizenship information.
What happened
Label Health, LLC v. United American Supply, LLC, David Underwood, Arleta Taylor, and Al Taylor began when Label Health filed a complaint relying only on the parties’ different citizenships as the basis for federal jurisdiction.
The court noted that Label Health and one defendant are limited liability companies. An LLC’s citizenship depends on the citizenship of each of its members, but the complaint did not provide that information.
Judge Engelmayer directed counsel to amend the complaint or file a letter listing the citizenship of each member of Label Health and the LLC defendant by July 24, 2020. The order did not decide the underlying dispute.
The detailed version
- Label Health v. United American Supply · No. 1:20-cv-05161
- Paul Engelmayer
- July 7, 2020
Background
Label Health filed the complaint on July 6, 2020. It alleged that diversity of citizenship was the sole basis for federal subject-matter jurisdiction, meaning the federal court’s authority to hear the case based on the parties’ citizenships.
Jurisdictional issue
The court observed that Label Health and one defendant are limited liability companies. Under the rule cited by the court, an LLC has the citizenship of each of its members. The complaint did not list the citizenship of the members of Label Health or the LLC defendant, so the court could not yet determine whether diversity jurisdiction existed.
Order
The court directed counsel to amend the complaint or file a letter listing the citizenship of every member of Label Health and the LLC defendant by July 24, 2020. The order addressed only whether the complaint adequately established federal jurisdiction; it did not reach the merits of the parties’ dispute.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.