Roca-Barnett v. Caribbean International News Corp.
920 F. Supp. 2d 238
D.P.R.2013Background
- Roca-Barnett (Florida resident) sues CIN, Stein, and Pompadour under Puerto Rico law.
- Roca claims diversity jurisdiction and an amount in controversy exceeding $75,000.
- Roca asserts CIN is a Puerto Rico actor, while Stein and Pompadour are CIN directors/officers.
- The complaint does not specify the residency of Stein and Pompadour.
- Plaintiff seeks relief under Law 100, Law 69, Law 17, Law 80, and articles 1802-1803, but jurisdiction is at issue.
- The court sua sponte reviews subject-matter jurisdiction and dismisses for lack of complete diversity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether complete diversity exists for SJ jurisdiction | Roca asserts diversity of citizenship among parties | Diversity not established due to unknown domiciles of Stein/Pompadour and CIN’s citizenship | No complete diversity; jurisdiction not established. |
| Whether CIN’s citizenship is properly established | CIN is a Puerto Rico entity doing business there | CIN's principal place of business not shown to be outside Florida | Unable to prove CIN’s citizenship; no diversity. |
| Whether Stein and Pompadour’s citizenship were shown | 1/2 directors with residency not specified | Residences not provided; cannot determine domicile | Defendants’ domiciles not proven; no diversity. |
Key Cases Cited
- Padilla-Mangual v. Pavia Hosp., 516 F.3d 29 (1st Cir. 2008) (defines domicile for diversity purposes)
- Hertz Corp. v. Friend, 559 U.S. 77 (Supreme Court 2010) (corporation’s principal place of business is its nerve center)
- Exxon Mobil Corp. v. Allapattah Servs., Inc., 545 U.S. 546 (Supreme Court 2005) (complete diversity rules; single plaintiff from same state defeats jurisdiction)