Arthur Reid Stephenson, et al. v. Jaguar Land Rover North America, LLC, et al.

Summary

The United States District Court for the Northern District of California ordered Jaguar Land Rover North America, LLC to show cause why the action should not be remanded to state court for lack of subject matter jurisdiction. The court concluded that the removal papers sufficiently established the amount in controversy but failed to allege the plaintiffs’ state citizenship, as distinct from their residency, for purposes of diversity jurisdiction. Defendant was directed to respond by September 26, 2025, and plaintiffs could respond by October 3, 2025.

Holdings

1. For purposes of diversity jurisdiction, the citizenship of a natural person is determined by domicile rather than residence; allegations of residence alone are insufficient to establish citizenship.
2. The removing defendant did not establish federal subject matter jurisdiction because it failed to provide sufficient facts alleging the plaintiffs' state citizenship; the defendant therefore was required to show cause why the action should not be remanded.

Questions Presented

1. Whether the removal papers sufficiently established federal diversity subject matter jurisdiction by alleging the plaintiffs' citizenship.
2. Whether the case should be remanded for lack of subject matter jurisdiction.

Disposition

other