Case Law Summaries

New York – LLC - Diversity Jurisdiction

New YorkPlatinum-Montaur Life Sciences, LLC v. Navidea Bipoharmaceutical, Inc., No. 18-3535-cv, decided November 25, 2019. The U.S. Court of Appeals for the Second Circuit held that the district court erred by exercising diversity jurisdiction on the grounds that it did not have a good faith basis to believe that there was not complete diversity. Although it was difficult to ascertain the citizenship of an LLC party because of its complex ownership structure the district court should have remanded back to state court or ordered further discovery.

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