James G. Smith, et al. v. State Farm General Insurance Company, et al.

United States District Court for the Northern District of California

James G. Smith, et al. v. State Farm General Insurance Company, et al.

Trial Court Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 JAMES G. SMITH, et al., Case No. 25-cv-08005-WHO

8 Plaintiffs, ORDER REMANDING CASE v. 9 Re: Dkt. Nos. 21, 22 10 STATE FARM GENERAL INSURANCE COMPANY, et al., 11 Defendants.

12 13 During the parties’ December 16, 2025 Case Management Conference, counsel for 14 defendants raised a jurisdictional problem with this case. This matter was originally removed 15 from state court to federal court based on diversity jurisdiction, as defendant State Farm General 16 Insurance Company (“State Farm”) is domiciled in Illinois, whereas plaintiffs James Smith, Erin 17 Smith, and the Jefferson Street HOA (the “plaintiffs”) are all California residents. However, 18 counsel recently discovered that co-defendant Farmers Insurance Company (“Farmers”) is also 19 domiciled in California. See Phillips v. Boulet, No. 24-65,

2025 WL 1751998

, at *1 (E.D. La. 20 June 25, 2025) (indicating that Farmers is “domiciled . . . [in] California, and a citizen of the State 21 of California with its principal place of business in the State of California”); Hertz Corp. v. 22 Friend,

559 U.S. 77, 80

(2010) (finding corporations to be residents of the State of their “principal 23 place of business”). 24 Under

28 U.S.C. § 1332

, district courts have diversity jurisdiction over a case when the 25 dispute is between “citizens of different States.” This is a “complete diversity” requirement, 26 meaning that none of the plaintiffs may be from the same State as any of the defendants. Carden 27 v. Arkoma Assocs.,

494 U.S. 185, 187

(1990). Because plaintiffs and Farmers are both residents of 1 Accordingly, this case is REMANDED back to the Superior Court of California, County of San 2 || Francisco for all further proceedings. 3 IT IS SO ORDERED. 4 Dated: December 16, 2025 5 . 6 . Orrick 7 nited States District Judge 8 9 10 11 12

13

© 15 16

= 17

Z 18 19 20 21 22 23 24 25 26 27 28

Reference

Status
Unknown