Ike Beyale v. PHI Health, LLC, and John Doe

Summary

The United States District Court for the District of New Mexico sua sponte reviewed the sufficiency of a notice of removal based on diversity jurisdiction. The Court found that the notice inadequately alleged the plaintiff’s citizenship and did not trace the citizenship of the members of the defendant LLC through all required layers. It ordered the plaintiff and defendant to file Rule 7.1(a)(2) disclosure statements by January 20, 2026, warning that the case may be remanded if jurisdiction is not established.

Holdings

1. An allegation that the plaintiff is a resident of a state, without additional proof establishing domicile, is insufficient to establish citizenship for diversity jurisdiction.
2. An LLC is a citizen of every state in which any of its members is a citizen; corporate citizenship principles based on incorporation and principal place of business do not establish an LLC's citizenship.
3. The court ordered Plaintiff and Defendant to file disclosure statements fully complying with Federal Rule of Civil Procedure 7.1(a)(2), identifying the citizenship of every individual or entity whose citizenship is attributed to the party.

Questions Presented

1. Whether the notice of removal adequately alleged Plaintiff's citizenship for purposes of diversity jurisdiction.
2. Whether the notice of removal adequately established the citizenship of PHI Health, LLC by identifying the citizenship of its members and tracing the citizenship of nested LLC members through all necessary ownership layers.
3. Whether the parties should be ordered to file Rule 7.1(a)(2) citizenship disclosure statements to facilitate determination of subject matter jurisdiction.

Disposition

other