Mary Crawford v. Keith Harris and NFI Interactive Logistics LLC

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION MARY CRAWFORD, Plaintiff, Vv. Case No. 6:26-cv-106-JA-NWH KEITH HARRIS and NFI INTERACTIVE LOGISTICS LLC, Defendants.

ORDER This case is before the Court on review of the Notice of Removal (Doc. 1) filed by Defendant NFI Interactive Logistics LLC (NFI).

Federal courts are courts of limited jurisdiction. “[B]ecause a federal court is powerless to act beyond its statutory grant of subject matter jurisdiction, a court must zealously insure that jurisdiction exists over a case, and should itself raise the question of subject matter jurisdiction at any point in the litigation where a doubt about jurisdiction arises.” Smith v. GTE Corp., 236 F.3d 1292, 1299 (11th Cir. 2001).

In the Notice of Removal (Doc. 1), NFI bases subject-matter jurisdiction on diversity of citizenship under 28 U.S.C. § 1332. But NFI has not sufficiently alleged diversity of citizenship.

First, NFI has not properly identified Plaintiffs citizenship. NFI states merely that Plaintiff “a resident of Volusia County, Florida.” (Doc. 1 § 10).

However, it is “domicile’—not merely “residence’—that determines an individual’s citizenship for diversity purposes. See McCormick v. Aderholt, 293 F.3d 1254, 1257-58 (11th Cir. 2002) (per curiam). NFI’s allegations of. “residence” are not sufficient to establish Plaintiffs citizenship.

Second, NFIT’s allegations regarding its own citizenship are not sufficient either. NFI states that it “is a foreign corporation with its principal place of business in... New Jersey.” (Doc. 1 ¥11). But a description of itself as a “foreign corporation” is not an indication of where NFI is incorporated; “negative” allegations of citizenship are not sufficient.

Finally, the Notice of Removal does not identify the citizenship of the codefendant, Keith Harris.

Accordingly, it is ORDERED that no later than January 26, 2026, Defendant NFI Interactive Logistics LLC shall file an amended notice of removal that establishes that Plaintiff and Defendants are of diverse citizenship.

DONE and ORDERED in Orlando, Florida» en Jan ry 10: 2026.

I Co JOHN ANTOON II United States District Judge Copies furnished to: Counsel of Record Unrepresented Parties