1700 Universe, LLC v. Seneca Insurance Co., Inc.
3:25-cv-00206
S.D. Miss.May 1, 2025Background
- The case concerns whether the federal court has subject-matter jurisdiction in a dispute between 1700 Universe, LLC and Seneca Insurance Company, Inc.
- 1700 Universe, LLC initially failed to properly disclose the citizenship of its members per Rule 7.1, despite multiple court orders mandating correct filings.
- After three attempts, 1700 Universe, LLC finally filed a correct disclosure statement listing all its members and their citizenships.
- Seneca Insurance Company’s Notice of Removal incorrectly alleged the citizenship of 1700 Universe, LLC and failed to properly state its own citizenship (principal place of business and state of incorporation).
- The court had scheduled, but then canceled, an in-person hearing due to 1700 Universe's compliance, though it noted significant court resources had been expended on this issue.
- The court ordered Seneca to file corrected disclosures and an amended Notice of Removal, warning of possible remand for noncompliance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 1700 Universe, LLC complied with Rule 7.1 | Refiled and provided correct disclosure | N/A | Plaintiff now compliant |
| Whether Seneca properly established federal jurisdiction | N/A | Removal based on incorrect citizenship allegations | Defendant failed; must amend |
| Sufficiency of Rule 7.1 corporate disclosure statements | Filed proper statement after initial failures | Filed disclosure missing principal place of business | Defendant must file correct statement |
| Necessity of in-person hearing for disclosure issues | Filed accurate disclosure | N/A | Hearing canceled |
Key Cases Cited
- Manguno v. Prudential Prop. & Cas. Ins. Co., 276 F.3d 720 (5th Cir. 2002) (removing party bears the burden of establishing federal jurisdiction)
- MidCap Media Fin., L.L.C. v. Pathway Data, Inc., 929 F.3d 310 (5th Cir. 2019) (corporate citizenship requires stating principal place of business and state of incorporation)
- Neeley v. Banker Tr. Co. of Tex., 757 F.2d 621 (5th Cir. 1985) (corporate citizenship allegations must be specific)
- Gutierrrez v. Flores, 543 F.3d 248 (5th Cir. 2008) (doubts about removal should be resolved in favor of remand)