Dispensa v. Good
2:25-cv-12017
| E.D. Mich. | Jul 29, 2025Background
- Plaintiff Christopher Francis Dispensa alleges that AEW and Jonathan David Good caused him injuries through an unscripted assault at a wrestling performance in Detroit.
- Dispensa initially filed the case in Wayne County Circuit Court, but AEW removed it to federal court, claiming diversity jurisdiction under 28 U.S.C. § 1332.
- AEW asserted its diverse citizenship via its status as a Delaware entity wholly owned by Beatnik Investments, LLC, itself owned by two trusts allegedly with Illinois citizenship through their trustees.
- The court questioned whether the record established subject-matter jurisdiction, directing AEW to clarify the citizenship of the LLC's members and trusts.
- AEW responded by submitting a redacted affidavit identifying the relevant individuals, and moved to file an unredacted version under seal.
- The court denied the motion to seal, citing a strong presumption of openness for judicial records, and required AEW to file the unredacted affidavit publicly or face remand to state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Graham Affidavit establishing jurisdiction can be filed under seal | Not the main movant, not specified | Sealing necessary to protect ownership/asset privacy | Motion to seal denied—no compelling justification |
| Whether court has subject-matter jurisdiction based on current filings | Implicitly: jurisdiction not established | Filed affidavits (redacted/sealed) establish diversity | Jurisdictional facts must be on public docket |
| Whether unsubstantiated privacy concerns can justify sealing | Not relevant | Ownership details merit confidentiality | Privacy concerns insufficient for sealing |
| Consequence if AEW does not file unredacted affidavit publicly | Not specified | Not specified | Case will be remanded to state court |
Key Cases Cited
- Shane Grp., Inc. v. Blue Cross Blue Shield of Mich., 825 F.3d 299 (6th Cir. 2016) (strong presumption in favor of openness for court records; party seeking to seal must provide compelling reason)
- Baxter Int’l, Inc. v. Abbott Lab’ys, 297 F.3d 544 (7th Cir. 2002) (party seeking secrecy must give detailed analysis, document by document)