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Hansen Ranch, LLC v. Fireman's Fund Insurance Company
5:25-cv-06680
| N.D. Cal. | Aug 11, 2025
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Background

  • Plaintiffs (Hansen Ranch LLC and Hawkins Ranch LLC) filed an insurance coverage case originally in Santa Clara County Superior Court.
  • Defendants (Fireman's Fund Insurance Co. and National Surety Corp.) removed the case to federal court, invoking diversity jurisdiction under 28 U.S.C. § 1332.
  • The removal notice asserted that Plaintiffs are LLCs based in California and Defendants are corporations headquartered in Illinois.
  • The defendants claimed the amount in controversy requirement was satisfied.
  • The federal court questioned whether the required complete diversity of citizenship is met, because the removal notice did not properly establish the citizenship of all LLC members.
  • The court issued an order to defendants to show cause, by a specific deadline, why the case should not be remanded to state court for lack of federal subject matter jurisdiction.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether federal subject matter jurisdiction exists Implicitly contests removal Federal court has diversity jurisdiction Not yet decided; defendants must show cause
Proper test for LLC citizenship for diversity Implied: test not met LLC citizenship based on principal place of business Removal notice used incorrect legal test
Sufficient facts supporting diversity Implied: insufficient facts Assumes proper facts provided (did not detail LLC member citizenship) Defendants failed to provide needed details
Amount in controversy requirement Not contested Satisfied (amount exceeds $75,000) Not in dispute—threshold satisfied

Key Cases Cited

  • Owen Equip. & Erection Co. v. Kroger, 437 U.S. 365 (federal courts have limited jurisdiction; party invoking jurisdiction bears the burden)
  • Scott v. Breeland, 792 F.2d 925 (burden is on party asserting federal jurisdiction; presumption against it)
  • Johnson v. Columbia Props. Anchorage, LP, 437 F.3d 894 (LLC citizenship determined by citizenship of each owner/member for diversity purposes)
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Case Details

Case Name: Hansen Ranch, LLC v. Fireman's Fund Insurance Company
Court Name: District Court, N.D. California
Date Published: Aug 11, 2025
Docket Number: 5:25-cv-06680
Court Abbreviation: N.D. Cal.