Beasley v. JPMorgan Chase Bank NA
2:24-cv-03708
D. Ariz.May 27, 2025Background
- Plaintiff James Craig Beasley, an Arizona resident, filed a lawsuit in Maricopa County Superior Court alleging negligence, negligence per se, and premises liability against JP Morgan Chase Bank NA.
- JP Morgan Chase Bank NA removed the case to federal court on the basis of diversity jurisdiction.
- Plaintiff amended his complaint to add Valley National Bank of Arizona, an Arizona corporation, as a defendant.
- The addition of Valley National Bank potentially destroyed complete diversity because both Plaintiff and the added defendant are citizens of Arizona.
- Plaintiff moved to remand the case back to state court, contending the absence of complete diversity removed federal subject matter jurisdiction.
- The District Court reviewed the parties' citizenship and the requirements for federal jurisdiction under 28 U.S.C. § 1332.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether complete diversity exists post-amendment | Addition of Valley National destroys diversity | (Not stated/opposed) | No complete diversity; remand required |
| Whether the case should be remanded | Federal court lacks subject jurisdiction | (Not stated/opposed) | Case remanded to state court |
Key Cases Cited
- Valdez v. Allstate Ins. Co., 372 F.3d 1115 (9th Cir. 2004) (removing party bears burden to establish federal subject matter jurisdiction)
- Hunter v. Philip Morris USA, 582 F.3d 1039 (9th Cir. 2009) (jurisdiction assessed at the time of removal; complete diversity required)
- Emrich v. Touche Ross & Co., 846 F.2d 1190 (9th Cir. 1988) (burden on removing party to prove federal jurisdiction)
- Geographic Expeditions, Inc. v. Estate of Lhotka ex rel. Lhotka, 599 F.3d 1102 (9th Cir. 2010) (strong presumption against removal jurisdiction)