Rockford Mutual Insurance Co. v. L.P. Partners Limited Partnership, 3:17-cv-00631

Rockford Mutual Insurance Company filed a diversity-based declaratory-judgment complaint against L.P. Partners Ltd. Partnership and several necessary-party defendants, including a land trust, individuals (Nathan and Tabbatha Phelps), two LLCs (IBIN Management, LLC and IBIN Indian Springs LLC), and Fannie Mae.
Rockford alleged its own citizenship as Illinois (incorporated and principal place of business in Illinois).
Rockford pleaded only residences (not domiciles) for the individual defendants and alleged organizational forms and Indiana addresses for several business entities, but failed to identify the citizenship of members/partners/trustee.
Rockford used phrases like "upon information and belief" regarding L.P.’s partners and the trust beneficiary instead of alleging personal-knowledge facts about citizenship.
The magistrate judge found these jurisdictional allegations deficient because diversity requires citizenship (domicile for individuals; members’/partners’ citizenship for unincorporated entities; trustee citizenship for trusts) and ordered Rockford to file an amended complaint tracing citizenship through all ownership layers by a set deadline.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether federal diversity jurisdiction properly alleged	Rockford asserted diversity jurisdiction and alleged its own citizenship and residential/organizational facts for others	Defendants (implicitly) challenged adequacy of citizenship pleadings by being unestablished	Court held Rockford failed to plead citizenship adequately and must amend
Sufficiency of alleging residence vs. domicile for individuals	Rockford alleged the Phelpses reside in LaPorte County, Indiana	Court: residence alone insufficient; must plead domicile (intent to remain)	Court required citizenship/domicile allegations, not mere residence
Citizenship pleading for LLCs and LPs	Rockford alleged LLCs and the LP are Indiana entities with Indiana addresses	Court: unincorporated entities’ citizenship equals that of each member/partner and must be traced through all layers	Court required identification of each member/partner and their citizenships
Citizenship of a land trust	Rockford alleged the trust exists under Indiana law and that L.P. is beneficiary; listed trustee address	Rockford focused on beneficiary and trustee’s Indiana address	Court: trust’s citizenship is that of the trustee; Rockford failed to clarify trustee’s entity type and citizenship	Court required clarity on trustee’s identity, entity type, and citizenship

Chase v. Shop’n Save Warehouse Foods, Inc., 110 F.3d 424 (7th Cir.) (party invoking diversity bears burden to prove complete diversity)
Mutual Assignment & Indem. Co. v. Lind-Waldock & Co., LLC, 364 F.3d 858 (7th Cir.) (failure to trace citizenship can result in dismissal/remand)
N. Trust Co. v. Bunge Corp., 899 F.2d 591 (7th Cir.) (corporation’s citizenship is state of incorporation and principal place of business)
Guar. Nat’l Title Co. v. J.E.G. Assocs., 101 F.3d 57 (7th Cir.) (alleging residence not citizenship; limited partnerships have citizenships of each partner)
Held v. Held, 137 F.3d 998 (7th Cir.) (when only residence alleged, court must dismiss for lack of properly pleaded citizenship)
Cosgrove v. Bartolotta, 150 F.3d 729 (7th Cir.) (LLC citizenship is determined by citizenship of its members)
Meyerson v. Showboat Marina Casino P’ship, 312 F.3d 318 (7th Cir.) (citizenship of unincorporated associations must be traced through all layers)
Hart v. Terminex Int’l, 336 F.3d 541 (7th Cir.) (limited partnership’s citizenship includes each general and limited partner)
Grede v. Bank of N.Y. Mellon, 598 F.3d 899 (7th Cir.) (a trust’s citizenship is that of its trustee)
Carden v. Arkoma Assocs., 494 U.S. 185 (U.S. Supreme Court) (unincorporated associations’ citizenship must be traced through partners/owners)