Label Health, LLC v. Haywire Consulting, Inc.
- Vernon Broderick
- 1:20-cv-05640
- U.S. District Court · Southern District of New York
- 2
In Label Health v. Haywire, Judge Aaron ordered Label Health to identify its members’ citizenship before the court could assess diversity jurisdiction.
Label Health, LLC, because it was required to provide information about the identity and citizenship of each of its members before the court could determine whether diversity jurisdiction existed.
What happened
In Label Health, LLC v. Haywire Consulting, Inc., the court had asked Label Health, a limited liability company, to provide the citizenship of each of its members. Label Health instead filed affidavits stating that David Miller and Jeffery Miller were its co-founders and that each lived in New York, and that the company was organized and headquartered in New York.
The court explained that a limited liability company has the citizenship of its members. Because the affidavits did not identify any member or provide each member’s citizenship, the court could not determine whether complete diversity existed or whether it had authority to hear the case on that basis.
Judge Aaron ordered Label Health to file an affidavit or declaration identifying every member and stating each member’s citizenship by April 1, 2021. The order did not dismiss the case or otherwise decide the parties’ underlying dispute.
The detailed version
- Label Health, LLC v. Haywire Consulting, Inc. · No. 1:20-cv-05640
- Vernon Broderick
- Mar. 25, 2021
Background
The court had previously directed Label Health, LLC, to file an affidavit or declaration stating the citizenship of each of its members. Label Health filed affidavits from David Miller and Jeffery Miller. Those affidavits stated that Miller and Miller were the company’s co-founders and that each resided in New York State. They also stated that Label Health was organized under New York law and had its principal place of business in New York State.
Jurisdictional issue
The court explained that a limited liability company takes the citizenship of its members. For a case based on diversity jurisdiction—the federal court’s authority to hear certain disputes between citizens of different states—the complaint must identify the citizenship of each individual member and the relevant business information for any corporate member. The affidavits did not identify any member of Label Health or state the citizenship of each member. As a result, the court had no basis to determine whether complete diversity existed or to exercise diversity jurisdiction.
Order
The court ordered Label Health to file, no later than April 1, 2021, an affidavit or declaration expressly stating the identity and citizenship of each member of Label Health, LLC. The opinion did not dismiss the case, rule on the underlying dispute, or state whether complete diversity ultimately existed.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.