Peet v. Stewart

District Court, E.D. Missouri·Decided September 16, 2025·No. 1:25-cv-00053·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI SOUTHEASTERN DIVISION

GREGORY ALLEN PEET, SR., ) ) Plaintiff, ) v. ) Case No. 1:25-cv-00053-SNLJ ) ROGER ALLAN STEWART, et al., ) ) Defendants. )

MEMORANDUM AND ORDER TO SHOW CAUSE

This matter is before the Court sua sponte on the issue of subject-matter jurisdiction. In this action raising issues of purely state law, plaintiff invokes diversity jurisdiction under 28 U.S.C. § 1332(a). After reviewing the record, the Court finds that plaintiff has failed to establish diversity jurisdiction. As such, plaintiff is ordered to show cause why this matter should not be dismissed for lack of subject-matter jurisdiction. I. SUBJECT-MATTER JURISDICTION “Federal courts are courts of limited jurisdiction” and “[t]hey possess only that power authorized by [the U.S.] Constitution and statute[s].” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994). It is “presumed that a cause lies outside this limited jurisdiction and the burden of establishing the contrary rests upon the party asserting jurisdiction.” Id. (cleaned up). Because jurisdiction is a threshold question, “[c]ourts have an independent obligation to determine whether subject-matter jurisdiction exists, even when no party challenges it.” Hertz Corp. v. Friend, 559 U.S. 77, 94 (2010); see also Hart v. United States, 630 F.3d 1085, 1089 (8th Cir. 2011) (stating a court has an obligation to sua sponte consider whether subject-matter jurisdiction exists); Fed.R.Civ.P 12(h)(3) (“If the court determines at any time that it lacks subject-matter jurisdiction, the

court must dismiss the action.”). The court must be satisfied that it has jurisdiction before addressing the merits of other legal arguments. Carlson v. Arrowhead Concrete Works, Inc., 445 F.3d 1046, 1050 (8th Cir. 2006). Because subject-matter jurisdiction involves the court’s power to adjudicate a case, it cannot be forfeited or waived. Thigulla v. Jaddou, 94 F.4th 770, 773 (8th Cir. 2024). To invoke diversity jurisdiction, the amount in controversy must exceed $75,000,

and there must be complete diversity of citizenship among the parties. 28 U.S.C. § 1332(a). “If any plaintiff is a citizen of the same state as any defendant, there is not ‘complete diversity’” and the federal court lacks jurisdiction. Great River Entm’t, LLC v. Zurich Am. Ins. Co., 81 F.4th 1261, 1262 (8th Cir. 2023). “For purposes of federal jurisdiction, ‘domicile’ and ‘citizenship’ are synonymous terms.” Eckerberg v. Inter-

State Studio & Publ’g Co., 860 F.3d 1079, 1086 (8th Cir. 2017). Domicile and residence are not synonymous terms; an individual “can reside in one place but be domiciled in another.” Id. at 1084. An individual “acquires a domicile of origin at birth, and that domicile continues until a new one (a domicile of choice) is acquired.” Id. at 1085 (cleaned up). “To establish domicile, an individual must both be physically present in the

state and have the intent to make his home there indefinitely.” Id. A court determines intent based on objective factors, including “declarations, exercise of civil and political rights, payment of taxes, obtaining of licenses, location of business or occupation, and ownership of property.” Id. II. DISCUSSION Plaintiff has brought state law claims against the defendants in this Court based on

an assertion of diversity jurisdiction under § 1332(a). [Doc. 28]. He filed his original complaint on March 24, 2025 [Doc. 1], and an amended complaint on April 15, 2025 [Doc. 28]. “It is well-established that an amended complaint supercedes an original complaint and renders the original complaint without legal effect.” In re Atlas Van Lines, Inc., 209 F.3d 1064, 1067 (8th Cir. 2000). As a result, the Court must determine whether there is subject-matter jurisdiction based on the amended complaint. Id.

The defendants include two corporations, a limited liability company, and four individuals. A corporation is a citizen of the state where it is incorporated and the state where its principal place of business is located. 28 U.S.C. § 1332(c). For a limited liability company (LLC), its citizenship is determined by the citizenship of its members. GMAC Commercial Credit LLC v. Dillard Dept. Stores, Inc., 357 F.3d 827, 828-829 (8th

Cir. 2004). An individual can be a resident of multiple states but is only a citizen of one state. Hargett v. RevClaims, LLC, 854 F.3d 962, 965 (8th Cir. 2017). “A complaint or notice of removal resting on residency, then, will not establish citizenship for diversity jurisdiction.” Id. In the amended complaint, plaintiff alleges that he is a resident of Kentucky, and

the defendants are residents of Missouri and Tennessee. [Doc. 28 at ¶¶ 1-11]. Because plaintiff states the parties’ residency, as opposed to their citizenship, he fails to establish diversity jurisdiction. Further, although he states the facts relevant to citizenship for one corporate defendant, he fails to state the state of incorporation for the other corporate defendant. See [Id. at ¶ 4, 5]. He also fails to state the citizenship of the members of the LLC defendant. See [Id. at ¶ 4, 5, 8].

Because plaintiff has failed to establish diversity jurisdiction, he is ordered to show cause within 14 days as to why this case should not be dismissed. He may do so by filing a response to this Order that clearly states the citizenship of each defendant. Defendants will be allowed to submit a reply. Further, plaintiff must provide proof of his citizenship as of March 24, 2025 (when the case was filed) and April 15, 2025 (when the amended complaint was filed). A

statement of citizenship based solely on an address will not be sufficient. When this case was filed, plaintiff claimed a Kentucky address as his residence. [Doc. 2]. But a document mailed by the Clerk’s Office to plaintiff at the Kentucky address was returned as undeliverable on April 24, 2025 with a handwritten note stating, “not here return to sender.” [Doc. 33]. All other filing notices in this case were sent to an email address at

plaintiff’s request. [Doc. 2]. Exhibits submitted by the parties in this matter show two addresses for plaintiff in Sikeston, Missouri, and a mobile phone number for plaintiff with a Missouri area code. [Docs. 28-12 at 14; 28-13 at 2; 28-16 at 3, 4, 5, 7; 28-25 at 1-3; 38-3 at 4-5; 38-5 at 13; 38-7 at 2; 47-20 at 24, 25]. There are also exhibits showing that the truck and trailer at

issue in this case were owned by “Peet Trucking” with an address in Sikeston, Missouri. [Doc. 28-26 at 3, 4].

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