Friday, December 27, 2013

Belleville Catering Co. v. Champaign Market Place, LLC case brief

Belleville Catering Co. v. Champaign Market Place, LLC case brief summary
350 F.3d 691 (7th Cir. 2003)

Plaintiffs, a corporation and its guarantors, sued defendant corporation, invoking diversity jurisdiction pursuant to 28 U.S.C.S. § 1332. Defendant counterclaimed. A jury trial was held in the United States District Court for the Central District of Illinois, ending in a verdict of $ 220,000 in defendant's favor on the counterclaim. Plaintiffs appealed.

Plaintiff corporation asserted it was a citizen of Missouri, as were its guarantors. The complaint also alleged that defendant was a Delaware limited liability company (LLC), with its principal place of business in Illinois. The court noted that counsel and the trial judge assumed that a LLC was treated like a corporation and thus was a citizen of its state of organization and its principal place of business. That was incorrect. Rather, LLCs were citizens of every state of which any member was a citizen. Furthermore, plaintiff corporation appeared to be incorporated in Illinois rather than Missouri. Defense counsel related that several of its members were citizens of Illinois.


  • As citizens of Illinois were on both sides of the suit, the court lacked diversity jurisdiction. 
  • Moreover, defense counsel stated that one of its members was another LLC that was asserting confidentiality for the members of the LLC. 
  • The court held that it was not possible to litigate under diversity jurisdiction with details kept confidential from the judiciary. 
  • Thus, federal jurisdiction had not been established. 
  • Lastly, the court ordered counsel to continue their representation without additional fees.
The judgment of the district court was vacated, and the proceeding was remanded with instructions to dismiss the complaint for want of subject-matter jurisdiction.

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