Pall Corporation v. Cleanspace Modular, LLC
- Rochon
- 1:23-cv-02082
- U.S. District Court · Southern District of New York
- 2
In Pall Corporation v. Cleanspace Modular, Judge Rochon ordered Pall to disclose information needed to establish diversity jurisdiction.
Pall Corporation must provide information identifying Cleanspace Modular, LLC’s members and their citizenship so the court can evaluate diversity jurisdiction.
What happened
Pall Corporation sued Cleanspace Modular, LLC, asserting that the court could hear the case because the parties were citizens of different states. Pall alleged that it was incorporated and headquartered in New York and that Cleanspace was incorporated and headquartered in Pennsylvania.
The court explained that an LLC’s citizenship depends on the citizenship of all its members, including members further up the ownership chain. Pall had not filed the required disclosure identifying Cleanspace’s members and their citizenship.
Judge Jennifer L. Rochon ordered Pall to file a completed disclosure statement by March 21, 2023, containing the information needed to establish diversity jurisdiction. The order did not decide the underlying dispute.
The detailed version
- Pall Corporation v. Cleanspace Modular, LLC · No. 1:23-cv-02082
- Rochon
- Mar. 14, 2023
Background
Pall Corporation filed a complaint against Cleanspace Modular, LLC. The complaint alleged subject-matter jurisdiction based on diversity of citizenship. Pall alleged that it was incorporated in New York and had its principal place of business there. It alleged that Cleanspace was a foreign limited liability company incorporated in Pennsylvania with its principal place of business in Pennsylvania.
Court’s analysis
The court explained that a corporation is a citizen of both its state of incorporation and the state where it has its principal place of business. An LLC, however, is a citizen of every state where its members are citizens. If an LLC’s members include other non-corporate entities, the citizenship inquiry must continue through the ownership chain until the citizenship of every individual and corporation with a direct or indirect interest is identified.
Federal Rule of Civil Procedure 7.1 requires a party to file a disclosure statement with its first appearance or pleading. The required form asks a plaintiff to identify each LLC member and state each member’s citizenship. Pall had not filed that statement.
Order
The court ordered Pall to file a completed Rule 7.1 disclosure statement by March 21, 2023. The statement must include the information necessary to establish subject-matter jurisdiction based on diversity of citizenship. The opinion addressed jurisdictional disclosure requirements and did not decide the parties’ underlying dispute.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.