Harris v. Estrada

CourtDistrict Court, D. New Mexico
DecidedMarch 3, 2025
Docket1:25-cv-00053
StatusUnknown

This text of Harris v. Estrada (Harris v. Estrada) is published on Counsel Stack Legal Research, covering District Court, D. New Mexico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Harris v. Estrada, (D.N.M. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

CRAIG MITCHELL HARRIS, ) ) Plaintiff, ) ) v. ) Case 1:25-cv-0053-KK-KRS ) ISMAEL ESTRADA and SAIA MOTOR ) FREIGHT LINE, LLC., ) ) Defendants. ) ORDER TO AMEND NOTICE OF REMOVAL THIS MATTER is before the Court sua sponte upon its review of the Notice of Removal. Plaintiff filed a Complaint for Damages against Defendants Ismael Estrada and Saia Motor Freight Line, LLC (“Saia”) in the Second Judicial District, Bernalillo County, New Mexico (Doc. 1-2), which Defendants removed to this Court on January 16, 2025, asserting federal court subject matter jurisdiction based on diversity of citizenship, 28 U.S.C. § 1332 (a). (Doc. 1 ¶ 3). “Federal courts ‘have an independent obligation to determine whether subject-matter jurisdiction exists, even in the absence of a challenge from any party,’ and thus a court may sua sponte raise the question of whether there is subject matter jurisdiction ‘at any stage in the litigation.’” Image Software, Inc. v. Reynolds & Reynolds Co., 459 F.3d 1044, 1048 (10th Cir. 2006) (quoting Arbaugh v. Y & H Corp., 546 U.S. 500, 514 (2006)). As the parties asserting federal jurisdiction, Defendants bear the burden of pleading and proving subject matter jurisdiction. Anderson v. XTO Energy, Inc., 341 F. Supp. 3d 1272, 1275 (D.N.M. 2018). Having considered Defendants’ jurisdictional allegations, the applicable law, and being otherwise fully advised in the premises, the Court concludes that the Notice of Removal fails to allege the necessary facts to sustain diversity jurisdiction. To invoke diversity jurisdiction, “a party must show that complete diversity of citizenship exists between the adverse parties and that the amount in controversy exceeds $75,000.” Dutcher v. Matheson, 733 F.3d 980, 987 (10th Cir. 2013). Complete diversity means that no plaintiff may be a citizen of the same state as any defendant. Id. “[F]or purposes of determining the existence of

diversity jurisdiction, the citizenship of the parties is to be determined with reference to the facts as they existed at the time of filing.” Grynberg v. Kinder Morgan Energy Partners, L.P., 805 F.3d 901, 905 (10th Cir. 2015) (internal quotation marks and citations omitted). Typically, the required showing to invoke diversity jurisdiction is satisfied by the removing defendant filing “a notice of removal ‘containing a short and plain statement of the grounds for removal.’” Dart Cherokee Basin Operating Co., LLC v. Owens, 574 U.S. 81, 87 (2014) (quoting 28 U.S.C. § 1446(a)); see, e.g., McEntire v. Kmart Corp., No. CIV 09-0567 JB/LAM, 2010 WL 553443, at *3 (D.N.M. Feb. 9, 2010) (“At the point of the filing of the notice of removal, … the defendant need only state the facts upon which jurisdiction is based.” (citing Laughlin v. Kmart Corp., 50 F.3d at 873 (“[T]he requisite amount in controversy and the existence of diversity must be affirmatively established

on the face of either the petition or the removal notice.”) (emphasis added))) Citizenship of an Individual Citizenship of an individual for diversity-jurisdiction purposes is determined by a person’s domicile, and a person’s domicile is defined as the place in which the party has a residence in fact and an intent to remain indefinitely, as of the time of the filing of the lawsuit. See Crawley v. Glaze, 710 F.2d 776, 678 (10th Cir. 1983). Generally speaking, “an allegation that a party ... is a resident of a state is not equivalent to an allegation of citizenship and is insufficient to confer jurisdiction upon the District Court.” Siloam Springs Hotel, L.L.C. v. Century Surety Co., 781 F.3d 1233, 1238 (10th Cir. 2015). The Notice of Removal alleges that, “[a]ccording to his Complaint and upon other information and belief, Plaintiff Craig Mitchell Harris is a resident and citizen of Bernalillo County, New Mexico.” (Doc. 1 ¶ 7). The state court complaint actually alleges only that Harris is a resident of New Mexico. Defendants’ allegation that Harris is a citizen of New Mexico is a legal

conclusion based on Plaintiff’s allegation of his residence. While “allegations of mere ‘residence’ may not be equated with ‘citizenship’ for the purposes of establishing diversity,” Whitelock v. Leatherman, 460 F.2d 507, 514 (10th Cir. 1972), it is also true that “a person’s place of residence is prima facie evidence of his or her citizenship.” McEntire, 2010 WL 553443, at *3 (citing State Farm Mut. Auto. Ins. Co. v. Dyer, 19 F.3d 514, 520 (10th Cir. 1994)). Accordingly, subject to any challenge Plaintiff might raise, Defendant has adequately alleged that Plaintiff is a citizen of New Mexico based upon Plaintiff’s allegation in the state court complaint that he resides in that state. See, e.g., Lee v. BMW of N.A, LLC, No. SACV 19-01722 JVS (ADSx), 2019 WL 6838911, at *2 (C.D. Cal. Dec. 16, 2019) The Notice of Removal also alleges that “Defendant Ismael Estrada is a resident of El Paso

County, Texas.” (Doc. 1, ¶ 8). Again, however, residency is not synonymous with citizenship, and therefore this allegation is insufficient to allege diversity jurisdiction. See, e.g., Travaglio v. Am. Exp. Co., 735 F.3d 1266, 1269 (11th Cir. 2013) (“The allegations in Travaglio’s complaint about her citizenship are fatally defective. Residence alone is not enough.”); Simon v. Taylor, 455 F. App’x 444, 446 (5th Cir. 2011) (“an allegation that the parties are ‘residents’ of particular states is insufficient to provide the court with diversity jurisdiction”); Kantrow v. Celebrity Cruises Inc., 533 F. Supp. 3d 1203, 1215 (S.D. Fla. 2021) (citing additional cases). This is more than a mere technical defect in Defendant Estrada’s allegation regarding his own citizenship. Not only is it possible for “one [to] reside in one place but be domiciled in another,” Miss. Band of Choctaw Inds. v. Holyfield, 490 U.S. 30, 48 (1989), it is not that uncommon for an individual to do so. Furthermore, delay in requiring Defendants to clarify the matter would “only compound[ ] the problem if, despite much time and expense having been dedicated to the case, a lack of jurisdiction causes it to be dismissed.” Lowe v. Travelers Home & Marine Ins. Co., No. 19-CV-00983-PAB,

2019 WL 1615070, at *1 (D. Colo. Apr. 15, 2019). Citizenship of an LLC The Notice of Removal alleges that Defendant SAIA is a limited liability company formed in the state of Georgia with its principal place of business also in Georgia. (Doc. 1 ¶ 9). This allegation incorrectly uses the legal test for determining the citizenship of a corporation for determining the citizenship of a limited liability company (“LLC”). That is, a corporation is “deemed to be a citizen of any State by which it has been incorporated and of the State where it has its principal place of business.” Gadlin v.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Mississippi Band of Choctaw Indians v. Holyfield
490 U.S. 30 (Supreme Court, 1989)
Carden v. Arkoma Associates
494 U.S. 185 (Supreme Court, 1990)
Arbaugh v. Y & H Corp.
546 U.S. 500 (Supreme Court, 2006)
Gadlin v. Sybron International Corp.
222 F.3d 797 (Tenth Circuit, 2000)
Image Software, Inc. v. Reynolds & Reynolds Co.
459 F.3d 1044 (Tenth Circuit, 2006)
C. L. Whitelock v. Delbert Leatherman
460 F.2d 507 (Tenth Circuit, 1972)
Richard Simon v. Heath Taylor
455 F. App'x 444 (Fifth Circuit, 2011)
Dutcher v. Matheson
733 F.3d 980 (Tenth Circuit, 2013)
Siloam Springs Hotel, L.L.C. v. Century Surety Co.
781 F.3d 1233 (Tenth Circuit, 2015)
Anderson v. Xto Energy, Inc.
341 F. Supp. 3d 1272 (D. New Mexico, 2018)
Travaglio v. American Express Co.
735 F.3d 1266 (Eleventh Circuit, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Harris v. Estrada, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harris-v-estrada-nmd-2025.