Narang v. Armour
- James Oetken
- 1:24-cv-01125
- U.S. District Court · Southern District of New York
- 3
In Narang v. Armour, Judge Oetken ordered Priya Narang to show jurisdiction or amend, warning that the action may be dismissed.
Priya Narang and the five named defendants: Troy Armour, Junk Kouture Operations Ireland LTD, Junk Kouture Entertainment and Media Group Limited LLC, Media Group Limited, and Junk Kouture Limited.
What happened
In Narang v. Armour, Priya Narang filed claims involving breach of contract and payment for services, but her complaint did not adequately explain why the federal court had authority to hear the case.
The court explained that the statute Narang cited concerns where a case may be filed, not whether the federal court has power over the dispute. The complaint also did not properly state the citizenship of all parties, including Troy Armour and the corporate defendants. For a limited liability company, the relevant citizenship is that of each member, and Narang’s residence alone did not establish her citizenship for this purpose.
Judge James Oetken gave Narang until March 7, 2024, either to explain why the complaint should not be dismissed for lack of federal-court authority or to ask to file an amended complaint that properly alleges jurisdiction. The court did not dismiss the action in this order.
The detailed version
- Narang v. Armour · No. 1:24-cv-01125
- James Oetken
- Feb. 20, 2024
Background
Priya Narang filed a complaint on February 15, 2024, asserting breach-of-contract and payment-for-services claims against Troy Armour, Junk Kouture Operations Ireland LTD, Junk Kouture Entertainment and Media Group Limited LLC, Media Group Limited, and Junk Kouture Limited. The complaint cited 28 U.S.C. § 1391(c)(3), but the court explained that this provision addresses venue—the proper place for a case to be heard—and does not itself provide federal subject-matter jurisdiction, meaning the court’s legal power to hear the case.
Jurisdictional Deficiencies
The court considered that Narang might intend to rely on diversity jurisdiction under 28 U.S.C. § 1332. That form of jurisdiction generally requires the citizenship of every plaintiff to differ from the citizenship of every defendant. The complaint did not identify the citizenship of each defendant and did not address Armour’s citizenship. Its blanket allegation that the corporate defendants were incorporated in or residents of Ireland was also insufficient.
The court further explained that the citizenship of a limited liability company depends on the citizenship of each of its members, not merely its place of registration or principal place of business. The complaint appeared to identify Junk Kouture Entertainment Media Group Limited LLC as a limited liability company but did not allege the citizenship of its members. The complaint’s statement that Narang had a residence in Fairfield County, Connecticut, was also insufficient because diversity citizenship is based on domicile—the person’s fixed home and intended permanent base—not residence alone.
Order
Because subject-matter jurisdiction can be considered at any time and a case must be dismissed if jurisdiction is absent, Judge James Oetken ordered Narang, by March 7, 2024, to either show cause why the complaint should not be dismissed for lack of subject-matter jurisdiction or move to file an amended complaint properly alleging jurisdiction. The order warned that the action may be dismissed if she failed to do so. The court did not dismiss the action or decide the contract-related claims in this order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.