Hatchel v. Trinity Operating (U S G) L L C, 5:21-cv-03361

Plaintiff Christopher Hatchel was injured during oilfield operations in Louisiana, resulting in partial amputation of his leg.
The incident allegedly stemmed from negligent supervision and safety failures by various contractors and personnel, including Trinity Operating, New Tech, Workrise, Simmons, Saunders, and later Miller and D&D Miller Consulting, LLC.
Suit was originally filed in Louisiana state court but removed to federal court on diversity jurisdiction grounds.
Hatchel sought to amend his complaint to add Miller and D&D (both Louisiana citizens) after learning their roles through discovery; he then moved to remand the case to state court, as adding non-diverse parties would defeat diversity jurisdiction.
Defendants opposed on grounds including alleged forum manipulation, futility of claims against Miller/D&D, and disputes over their citizenship.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Miller/D&D are Louisiana citizens	Miller and D&D are domiciled in Louisiana; thus, adding them destroys diversity	Miller's domicile uncertain (claimed Texas address); D&D may be Texas LLC	Court found Miller (and thus D&D) domiciled in Louisiana
Whether plaintiff was dilatory in seeking amendment	Not dilatory; roles only discovered after Miller's deposition in Sept. 2024	Had ample time; Miller identified early in discovery	Court found Hatchel was not dilatory
Whether a colorable claim exists against Miller/D&D	Colorable negligence claim based on failure of safety duties	No reasonable possibility of recovery; duties delegated; no actionable breach	Court found colorable claims exist against both Miller and D&D
Whether the purpose of amendment was to destroy jurisdiction	Sought amendment based on new evidence, not to defeat federal jurisdiction	Sole purpose is to defeat federal jurisdiction	Court found purpose was not solely to defeat jurisdiction; amendment appropriate
Whether remand is required after joinder of non-diverse defendants	Joinder of non-diverse parties destroys federal jurisdiction; case must be remanded	Joinder inappropriate; no remand should occur	Remand to state court required by statute and precedent

Hensgens v. Deere & Co., 833 F.2d 1179 (5th Cir. 1987) (sets standard for adding non-diverse defendants post-removal and balancing equities)
Wilson v. Bruks-Klockner, Inc., 602 F.3d 363 (5th Cir. 2010) (clarifies Hensgens factors and colorable claim standard for amendments)
Mas v. Perry, 489 F.2d 1396 (5th Cir. 1974) (explains domicile for diversity purposes)
Coury v. Prot, 85 F.3d 244 (5th Cir. 1996) (details factors for determining domicile in diversity cases)
Esco v. Smith, 468 So. 2d 1169 (La. 1985) (recognizes personal liability for supervisors failing safety duties)
Cobb v. Delta Exports, Inc., 186 F.3d 675 (5th Cir. 1999) (discusses amendment and jurisdictional impact of post-removal joinder of non-diverse parties)