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