Jordan's Ladder Legal Placements, LLC v. Major, Lindsey & Africa, LLC

Background

Jordan’s Ladder Legal Placements, LLC brought claims against Major, Lindsey & Africa, LLC. The opinion describes the parties as two limited liability companies engaged in legal recruiting. The complaint alleged, in general terms, that the parties were citizens of different states, but it did not identify the citizenship of every member of either LLC.

Jurisdiction issue

Federal courts may hear state-law claims under diversity jurisdiction only when the opposing parties are completely diverse. For an LLC, citizenship is determined by the citizenship of each member, not merely by the company’s place of incorporation or principal place of business. The court therefore needed information about every member of both LLCs.

The opinion identifies the only coercive claim as a state-law claim for tortious interference with contract. It also explains that the Federal Declaratory Judgment Act, 28 U.S.C. § 2201(a), does not independently create federal jurisdiction. Because the underlying claim was based on state law, the declaratory-judgment claim could proceed in federal court only if another basis for jurisdiction—such as complete diversity—existed.

Order

The court did not determine whether complete diversity existed, decide the tortious-interference claim, or dismiss the case. Instead, it ordered the parties to file a statement under oath identifying the state of residence of every member of each LLC by 12:00 noon on Friday, May 6, 2022. The requested information was intended to allow the court to determine whether it had subject-matter jurisdiction.