Jane Doe v. Three Rivers Behavioral Health, LLC; Universal Health Services, Inc.; and UHS of Delaware, Inc.

Summary

The United States District Court for the District of South Carolina denied Jane Doe’s motion to remand and alternative request for jurisdictional discovery. The court held that the defendants established complete diversity and that the amount-in-controversy requirement was satisfied, supporting federal jurisdiction over Doe’s state-law claims arising from alleged abuse at a behavioral health facility.

Holdings

1. An LLC is not assigned citizenship under the nerve-center test applicable to corporations; its citizenship is determined by tracing the citizenship of its members through the ownership structure. Three Rivers was therefore a citizen of Delaware and Pennsylvania.
2. UHS is a citizen of Delaware and Pennsylvania because the evidence established that Pennsylvania was the location of its corporate direction, control, and coordination.
3. Jurisdictional discovery was unwarranted because Plaintiff did not show that UHS's principal place of business was unclear or genuinely disputed in light of the defendants' competent evidence.
4. The amount-in-controversy requirement was satisfied because the alleged severe physical and emotional injuries, extended period of abuse, and claims for compensatory and punitive damages supported an amount exceeding $75,000 by a preponderance of the evidence. Because subject matter jurisdiction existed, remand was denied.

Questions Presented

1. Whether Three Rivers Behavioral Health, LLC's citizenship should be determined under the nerve-center test applicable to corporations rather than by tracing the citizenship of its members.
2. Whether UHS's principal place of business was in South Carolina because it allegedly delegated managerial functions to Three Rivers.
3. Whether Plaintiff was entitled to jurisdictional discovery concerning UHS's principal place of business.
4. Whether the amount-in-controversy requirement for diversity jurisdiction was satisfied.
5. Whether remand was required under 28 U.S.C. § 1447(c).

Disposition

remanded