Monica Helm v. Eastgate Associates - Diversity Jurisdiction Disclosure Order
Summary
The United States District Court for the Western District of Louisiana ordered plaintiff Monica Helm to file an amended Diversity Jurisdiction Disclosure Statement no later than April 9, 2026. The court found that Helm's original filing only stated she is 'an individual and resident of the State of Louisiana,' which is insufficient for diversity jurisdiction purposes, as domicile rather than residency determines citizenship. The court cited established Fifth Circuit precedent holding that residency alone does not satisfy the citizenship allegation requirement for federal diversity jurisdiction.
“Plaintiff must file, no later than April 9, 2026, an amended Diversity Jurisdiction Disclosure Statement that specifically alleges the state in which she is domiciled.”
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What changed
The court identified a deficiency in plaintiff Monica Helm's Diversity Jurisdiction Disclosure Statement filed under Docket 22. The original disclosure alleged only that she is 'an individual and resident of the State of Louisiana,' which the court found legally insufficient under Fifth Circuit precedent. The court granted leave to amend, requiring the plaintiff to file a corrected statement by April 9, 2026, specifically alleging her state of domicile rather than mere residency.\n\nParties appearing in federal court based on diversity jurisdiction should ensure their citizenship disclosures explicitly state domicile, not just residency. Federal courts routinely dismiss cases where diversity jurisdiction allegations are defective, and plaintiffs bear the burden of properly alleging citizenship for each named party.
What to do next
- Plaintiff must file, no later than April 9, 2026, an amended Diversity Jurisdiction Disclosure Statement that specifically alleges the state in which she is domiciled.
Archived snapshot
Apr 26, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
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April 2, 2026 Get Citation Alerts Download PDF Add Note
Monica Helm v. Eastgate Associates et al
District Court, W.D. Louisiana
- Citations: None known
- Docket Number: 5:25-cv-02036
Precedential Status: Unknown Status
Trial Court Document
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF LOUISIANA
SHREVEPORT DIVISION
MONICA HELM CIVIL ACTION NO. 25-cv-2036
VERSUS JUDGE S. MAURICE HICKS, JR.
EASTGATE ASSOCIATES ET AL MAGISTRATE JUDGE HORNSBY
MEMORANDUM ORDER
Plaintiff Monica Helm filed a Diversity Jurisdiction Disclosure Statement (Doc. 22)
and alleged that she is “an individual and resident of the State of Louisiana.” It is domicile
rather than mere residency that decides citizenship for diversity purposes, and “an
allegation of residency alone ‘does not satisfy the requirement of an allegation of
citizenship.’” Midcap Media Finance, LLC v. Pathway Data, Inc., 929 F.3d 310, 313 (Sth
Cir. 2019), quoting Strain v. Harrelson Rubber Co., 742 F.2d 888, 889 (Sth Cir. 1984). A
person may reside in multiple states simultaneously, but “[a]n individual who resides in
more than one State is regarded, for purposes of federal subject-matter (diversity)
jurisdiction, as a citizen of but one State.” Wachovia Bank v. Schmidt, 126 S. Ct. 941, 951 (2006). That is the state in which the person is domiciled. Id.; Acridge v. Evangelical
Lutheran Good Samaritan Soc., 334 F.3d 444, 451 (Sth Cir. 2003).
Plaintiff must file, no later than April 9, 2026, an amended Diversity Jurisdiction
Disclosure Statement that specifically alleges the state in which she is domiciled.
THUS DONE AND SIGNED in Shreveport, Louisiana, this 2nd day of April, 2026.
Mark L. Hornsby
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