Sonn v. Valashvili
- Vincent Briccetti
- 7:20-cv-08320
- U.S. District Court · Southern District of New York
- 2
In Sonn v. Valashvili, Judge Briccetti ordered counsel to explain each party’s citizenship so the court could determine diversity jurisdiction.
Heidi Sonn, her counsel, and the defendants were affected because the court required clarification of every party’s citizenship before determining whether the case could proceed in federal court.
What happened
In Sonn v. Valashvili, Heidi Sonn sued Lasha Valshvili, Lyft, Inc., Uber Technologies, Inc., Zwei-NY, LLC, and John Doe, claiming federal jurisdiction based on the parties’ citizenship.
The court explained that diversity jurisdiction requires every plaintiff to be a citizen of a different state from every defendant. The complaint alleged residences for Sonn and Valshvili, but residence alone does not establish citizenship. It also did not state the principal places of business of Lyft or Uber, and it did not identify the citizenship of Zwei-NY’s members.
The court ordered plaintiff’s counsel to submit a detailed letter by October 15, 2020, explaining every party’s citizenship so the court could decide whether it had jurisdiction. Judge Vincent Briccetti did not decide the underlying claims.
The detailed version
- Sonn v. Valashvili · No. 7:20-cv-08320
- Vincent Briccetti
- Oct. 8, 2020
Background
Heidi Sonn brought this action against Lasha Valshvili, Lyft, Inc., Uber Technologies, Inc., Zwei-NY, LLC, and John Doe. The complaint invoked diversity jurisdiction under 28 U.S.C. § 1332(a)(1), which allows certain disputes between citizens of different states to be heard in federal court.
Jurisdictional issue
The court explained that diversity jurisdiction requires complete diversity: each plaintiff must be a citizen of a different state from each defendant. An individual’s citizenship depends on domicile—the person’s fixed home and intended permanent home—not merely residence.
The complaint alleged that Sonn “resides” in California and that Valshvili “resides” in New York. The court held that these residence allegations alone did not establish their citizenship for diversity purposes.
The complaint alleged that Lyft and Uber were incorporated in Delaware but did not identify either corporation’s principal place of business. A corporation is a citizen of its state of incorporation and the state where it has its principal place of business. The complaint described Zwei-NY as a Delaware entity, but the court noted that it appeared to be a limited liability company. An LLC has the citizenship of each of its individual or entity members, and the complaint did not identify those members’ citizenship.
Order
The court ordered plaintiff’s counsel to submit, by October 15, 2020, a letter explaining in detail the citizenship of every party. The court did not dismiss the case or decide the underlying claims; it sought information needed to determine whether it had subject-matter jurisdiction.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.