Frank Smith, et al. v. Thomas Beck Robey, et al.

Summary

The United States District Court for the District of Arizona concludes that the complaint inadequately alleges the parties’ citizenship for purposes of diversity jurisdiction because it alleges residence rather than citizenship and relies on the parties’ domicile when the underlying events occurred. The court orders plaintiffs to file an amended complaint establishing the relevant jurisdictional facts by April 7, 2026, or the case will be dismissed without prejudice for lack of subject-matter jurisdiction.

Holdings

1. A complaint invoking diversity jurisdiction must establish complete diversity between all plaintiffs and all defendants and must allege sufficient jurisdictional facts to show the parties' citizenship.
2. An allegation that a natural person resides in a state does not establish that person's citizenship for purposes of diversity jurisdiction; citizenship depends on domicile.
3. Diversity jurisdiction is determined by the parties' citizenship and domicile at the time the complaint is filed, not at the time of the events giving rise to the action.

Questions Presented

1. Whether the complaint adequately alleged complete diversity of citizenship for purposes of federal diversity jurisdiction.
2. Whether allegations of residence establish the citizenship of natural persons for diversity-jurisdiction purposes.
3. Whether diversity jurisdiction is determined by the parties' domicile at the time of the events underlying the action or at the time the complaint is filed.

Disposition

other