Angel Russell, et al. v. Darian Patrick O’Brien, et al.

Summary

The United States District Court for the District of Arizona orders Domino’s Pizza, LLC to supplement its notice of removal by identifying the citizenship of all parties and explaining the relevance of snap removal. The court emphasizes that an unserved forum defendant does not cure a potential lack of complete diversity and sets a March 12, 2026 deadline for the supplement, along with standard case-management requirements.

Holdings

1. Alleging that parties are residents of Arizona is insufficient to establish diversity jurisdiction; the removing party must identify the citizenship of the plaintiffs and defendant O’Brien.
2. Domino’s must identify the citizenship of each of its members, tracing the citizenship through any intervening entities until reaching natural persons or corporations.
3. Snap removal does not cure the absence of complete diversity or permit removal of an action that could not originally have been filed in federal court.
4. The notice of removal did not establish federal jurisdiction, and Domino’s was required to file a supplement identifying the citizenship of each party and explaining how snap removal could be relevant.

Questions Presented

1. Whether the notice of removal adequately established the citizenship of all parties for purposes of diversity jurisdiction.
2. Whether Domino’s citizenship as a limited liability company could be established by identifying its state of organization and principal place of business rather than the citizenship of its members.
3. Whether snap removal could cure a lack of complete diversity or otherwise permit removal when an alleged in-state defendant and an alleged in-state plaintiff shared Arizona citizenship.
4. What supplemental information Domino’s was required to provide concerning federal subject-matter jurisdiction.

Disposition

other