Schneider v. Haley

CourtDistrict Court, N.D. Texas
DecidedMarch 17, 2025
Docket3:24-cv-02142
StatusUnknown

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

Bluebook
Schneider v. Haley, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

MELANIE SCHNEIDER, § § Plaintiff, § § v. § Civil Action No. 3:24-CV-02142-N § KIMBERLEY HALEY, et al., § § Defendants. §

MEMORANDUM OPINION AND ORDER

This Order addresses Plaintiff Melanie Schneider’s motion to remand [4] and Defendants Affordable Contractors Insurance, LLC (“ACI”), Kimberley Haley, Sean O’Keefe, and Timothy Allred’s motion to dismiss [3]. First, because the Court determines that Defendant Haley was improperly joined, the Court denies the motion to remand and dismisses Haley without prejudice. Then, the Court grants in part and denies in part Defendants’ motion to dismiss and grants Schneider leave to amend her pleadings against Defendants ACI, O’Keefe, and Allred following this Order. I. ORIGINS OF THE DISPUTE This case arises out of an insurance procurement dispute. Schneider is suing Defendants for several state-law causes of action related to the procurement of an insurance policy for a general contractor, Thomas Salmon, so that he could work on Schneider’s property. See generally Pl.’s First Am. Pet. [14-3]. ACI is an insurance agency, and O’Keefe is its owner and sole managing-member. Id. ¶ 23. Allred is a contractors insurance specialist at ACI. Id. ¶ 42. And Haley is a regional manager at ACI. Id. ¶ 48. Schneider alleges that Defendants unlawfully procured a policy for Salmon and provided him with a fraudulent Certificate of Liability Insurance (“COI”) on January 24, 2022, and then provided Salmon with another fraudulent COI on July 12, 2022, as the second COI

falsely represented that Schneider was an additional named insured on Salmon’s policy. Id. ¶¶ 29, 35, 58–61, 67. Schneider further alleges that Haley emailed the July 12, 2022, COI to Salmon, who then forwarded it to Schneider. Id. ¶ 47. Schneider filed this case in the 193rd judicial district of Dallas County, Texas, on July 22, 2024. See Pl.’s Orig. Pet. 1 [14-3]. Her claims include violations of the Texas

Business and Organizations Code; violations of the Texas Tax Code; violations of the Texas Insurance Code; violations of the Texas Deceptive Trade Practices-Consumer Protection Act (“DTPA”); fraud; fraudulent inducement; fraud by nondisclosure; negligence; breach of contract; conspiracy; and declaratory relief. ACI removed the case, invoking diversity jurisdiction as the basis for removal. Am.

Notice of Removal ¶ 9 [14]. ACI asserts that Haley has been improperly joined, so her citizenship should be disregarded for purposes of diversity jurisdiction. Id. ¶ 19. Schneider and Haley are both citizens of Texas, while ACI, O’Keefe, and Allred are citizens of Arizona. Id. ¶¶ 12–16. Schneider moves to remand the case, arguing that she properly joined Haley. Pl.’s Mot. Remand 5 [4]. Defendants also move to dismiss all Schneider’s

claims. Defs.’ Mot. Dismiss 5 [3]. II. LEGAL STANDARDS FOR REMAND AND IMPROPER JOINDER A defendant may remove a state court action to federal court if the defendant establishes the federal court’s original jurisdiction over the action. See 28 U.S.C. § 1441. To remove a case, a defendant must show that the action either arises under federal law or satisfies the requirements of diversity jurisdiction. See Beneficial Nat’l Bank v. Anderson, 539 U.S. 1, 6 (2003) (“[A]bsent diversity jurisdiction, a case will not be removable if the

complaint does not affirmatively allege a federal claim.”). For a federal court to have diversity jurisdiction, “all persons on one side of the controversy [must] be citizens of different states than all persons on the other side.” Harvey v. Grey Wolf Drilling Co., 542 F.3d 1077, 1079 (5th Cir. 2008) (citation omitted). Further, the amount in controversy must exceed $75,000. 28 U.S.C. § 1332(a).

When diversity jurisdiction is claimed, the doctrine of improper joinder allows a court to “ignore an improperly joined, non-diverse defendant in determining subject matter jurisdiction.” Ross v. Nationwide Prop. & Cas. Ins. Co., 2013 WL 1290225, at *2 (S.D. Tex. 2013) (citing Smallwood v. Ill. Cent. R.R. Co., 385 F.3d 568, 572 (5th Cir. 2004) (en banc)). “When a defendant removes a case to federal court on a claim of improper

joinder, the district court’s first inquiry is whether the removing party has carried its heavy burden of proving that the joinder was improper.” Smallwood, 385 F.3d at 576. This burden can be met by showing that either (1) there was actual fraud in the pleading of jurisdictional facts, or (2) the plaintiff is unable to establish a cause of action against the nondiverse defendant in state court. See Int’l Energy Ventures Mgmt., L.L.C. v. United

Energy Grp., Ltd., 818 F.3d 193, 205 (5th Cir. 2016) (citing Smallwood, 385 F.3d at 573). To establish the second category of improper joinder, the removing party must demonstrate that “there is no reasonable basis for the district court to predict that the plaintiff might be able to recover against a [nondiverse] defendant.” Id. Courts conduct a “Rule 12(b)(6)– type analysis” to determine whether a plaintiff has a reasonable basis for recovery against a nondiverse defendant. Int’l Energy, 818 F.3d at 200. If the plaintiff’s pleadings are sufficient to state a claim under the Rule 12(b)(6) plausibility standard, then there is a

reasonable basis to predict that the plaintiff could recover, and joinder is proper. Id. at 200–02. If the Court finds that a nondiverse party was improperly joined, “that party must be dismissed without prejudice.” Int’l Energy, 818 F.3d at 209; see also Flagg v. Stryker Corp., 819 F.3d 132, 136 (5th Cir. 2016) (en banc) (stating that “if the plaintiff improperly

joins a non-diverse defendant, then the court may disregard the citizenship of that defendant, dismiss the non-diverse defendant from the case, and exercise subject matter jurisdiction over the remaining diverse defendant”). III. THE COURT DENIES THE MOTION TO REMAND Defendants argue that Haley was improperly joined because there is no reasonable

basis to predict that Schneider could recover on her claims against Haley. Defs.’ Resp. 3 [10]. The Court addresses each of Schneider’s claims against Haley in turn. A. The Business Organizations Code and Tax Code Claims against Haley Fail

First, Schneider brings claims against Haley for ACI’s alleged violations of section 9.001 of the Texas Business Organizations Code and sections 171.252, 171.255, and 171.363 of the Texas Tax Code. Pl.’s First Am. Pet. ¶¶ 88–122. Under section 9.001 of the Business Organizations Code, to “transact business in this state, a foreign entity must register under this chapter if the entity: (1) is a . . . foreign limited liability company . . . the formation of which, if formed in this state, would require the filing under Chapter 3 of a certificate of formation.” TEX. BUS. ORGS. CODE § 9.001(a)(1). However, the Code authorizes the attorney general — not individuals — to bring suit to recover amounts due to Texas under section 9.001. Id. § 9.052. Similarly, sections 171.252, 171.255, and

171.363 of the Tax Code relate to forfeiture of corporate privileges and criminal liabilities and do not create a private right of action by which Schneider could recover from Haley. See TEX. TAX CODE §§ 171.252, 171.255, 171.363.

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