Castle 8604, LLC v. Selective Insurance Company

Summary

The United States District Court for the Southern District of Indiana denied Castle 8604, LLC's motion to maintain under seal portions of its Rule 7.1 Disclosure Statement identifying the company's members. The court held that the disclosure statement implicates subject-matter jurisdiction and that the plaintiff had not shown good cause for sealing it. The court ordered the statement unsealed after 21 days absent further objection or court action and required an amended disclosure addressing the domicile and permanent-resident status of each member or equity investor.

Holdings

1. Plaintiff did not show good cause for sealing the names of its members, because its generalized concerns about harassment and antisemitism did not establish that unsealing the disclosure statement would cause a particularized risk of harm.
2. A Rule 7.1 disclosure statement that bears directly on the court's subject matter jurisdiction is presumptively open to public view and may be sealed only upon a showing of good cause.
3. The disclosure statement was deficient because it did not state whether the Irish citizen identified as a source of plaintiff's citizenship was a lawful permanent resident of the United States domiciled in New Jersey, an exception that could defeat diversity jurisdiction.

Questions Presented

1. Whether plaintiff established good cause to maintain portions of its Rule 7.1 disclosure statement under seal.
2. Whether the Rule 7.1 disclosure statement adequately established complete diversity of citizenship for purposes of federal subject matter jurisdiction.
3. What remedial action should be taken regarding the deficient disclosure statement and the requested sealing.

Disposition

other