MSP Recovery Claims, Series LLC v. AIG Property Casualty Company
- Valerie Caproni
- 1:20-cv-02102
- U.S. District Court · Southern District of New York
- 2
In MSP Recovery Claims v. AIG Property Casualty, Judge Caproni granted defendants’ motion to dismiss for lack of standing, denied other motions as moot, and dismissed the case without prejudice.
MSP Recovery Claims, Series LLC and defendants AIG Property Casualty Company, AIG Property Casualty, Inc., and Lexington Insurance Company.
What happened
MSP Recovery Claims, Series LLC v. AIG Property Casualty Company was a case in which the defendants challenged whether the plaintiff had Article III standing—the constitutional requirement for bringing a case in federal court. The judgment relied on the court’s March 26, 2021 Opinion and Order.
The court granted the defendants’ motion to dismiss for lack of subject-matter jurisdiction. It denied as moot the defendants’ motions to strike the class allegations and for costs, declined to allow the plaintiff to amend its complaint again, and dismissed the matter without prejudice.
Judge Valerie Caproni’s ruling left the case closed. The judgment states that the plaintiff had already amended its complaint once and that another amendment would be futile because it had not adequately alleged standing.
The detailed version
- MSP Recovery Claims, Series LLC v. AIG Property Casualty Company · No. 1:20-cv-02102
- Valerie Caproni
- Mar. 29, 2021
Background
MSP Recovery Claims, Series LLC sued AIG Property Casualty Company, AIG Property Casualty, Inc., and Lexington Insurance Company. The judgment states that the plaintiff had not alleged Article III standing. Article III standing is the requirement that a plaintiff show a sufficient connection to the dispute to invoke the power of a federal court.
Rulings
The defendants moved under Rule 12(b)(1), which permits dismissal for lack of subject-matter jurisdiction. The court granted that motion because the plaintiff had not alleged Article III standing.
The defendants also moved to strike the class allegations and sought costs. The court denied those motions as moot, meaning it did not need to decide them after dismissing the case for lack of jurisdiction.
The court declined to grant the plaintiff leave to amend its complaint again. The judgment states that the plaintiff had already been allowed to amend once, had brought many similar cases, and had been on notice that standing was a central issue. The court therefore concluded that another amendment would be futile.
Disposition
The matter was dismissed without prejudice, and the case was closed. The judgment does not decide the underlying merits of the plaintiff’s claims; it resolves the case based on the jurisdictional standing requirement.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.