RMP Properties of Valdosta LLC v. Houston Specialty Insurance Co - Diversity Jurisdiction Disclosure Order
Summary
U.S. Magistrate Judge Mark L. Hornsby of the Western District of Louisiana ordered plaintiff RMP Properties of Valdosta, LLC to file an amended Diversity Jurisdiction Disclosure Statement no later than April 8, 2026. The court found the original disclosure insufficient because alleging an LLC is 'solely owned' by a named individual does not satisfy the specificity required under Fifth Circuit precedent for establishing federal diversity jurisdiction. The order cites Harvey v. Grey Wolf Drilling Co., Settlement Funding, L.L.C. v. Rapid Settlements, Ltd., and SXSW, L.L.C. v. Fed. Ins. Co. as governing authority.
“Plaintiff must file, no later than April 8, 2026, an amended Diversity Jurisdiction Disclosure Statement that clarifies whether Manojkumar Patel is its sole member.”
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What changed
The court issued a memorandum order requiring RMP Properties of Valdosta, LLC to amend its Diversity Jurisdiction Disclosure Statement. The original filing failed to meet Fifth Circuit specificity requirements because stating an LLC is 'solely owned' by an individual does not adequately allege the citizenship of LLC members as required by precedent. The court ordered the plaintiff to clarify whether Manojkumar Patel is its sole member, and if not, to set forth all members and their citizenship.\n\nParties subject to federal diversity jurisdiction requirements should ensure their disclosure statements specifically identify all members of any LLC party and the citizenship of each, rather than relying on ownership allegations. Failure to comply with this order could result in case dismissal or other sanctions for inadequate diversity jurisdiction.
What to do next
- Plaintiff must file, no later than April 8, 2026, an amended Diversity Jurisdiction Disclosure Statement that clarifies whether Manojkumar Patel is its sole member
Archived snapshot
Apr 24, 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 1, 2026 Get Citation Alerts Download PDF Add Note
R M P PROPERTIES OF VALDOSTA, LLC v. HOUSTON SPECIALTY INSURANCE CO, ET AL
District Court, W.D. Louisiana
- Citations: None known
- Docket Number: 5:26-cv-00962
Precedential Status: Unknown Status
Trial Court Document
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF LOUISIANA
SHREVEPORT DIVISION
R M P PROPERTIES OF VALDOSTA, LLC CIVIL ACTION NO. 26-cv-962
VERSUS JUDGE VAN HOOK
HOUSTON SPECIALTY INSURANCE CO, ET MAGISTRATE JUDGE HORNSBY
AL
MEMORANDUM ORDER
Plaintiff RMP Properties of Valdosta, LLC filed its Diversity Jurisdiction
Disclosure Statement (Doc. 9) and alleged that it is a Louisiana limited liability company
“solely owned by” Manojkumar Patel, who is domiciled in Georgia. The citizenship of an
LLC is determined by the citizenship of all of its members, with its state of organization or
principal place of business being irrelevant. Harvey v. Grey Wolf Drilling Co., 542 F.3d
1077 (5th Cir. 2008). “A party seeking to establish diversity jurisdiction must specifically
allege the citizenship of every member of every LLC or partnership involved in a
litigation.” Settlement Funding, L.L.C. v. Rapid Settlements, Ltd., 851 F.3d 530, 536 (5th
Cir. 2017). An allegation that an LLC is “solely owned” by someone is not enough to
allege citizenship with specificity. The party must set forth the members of the LLC, which
may be different from owners in some states. SXSW, L.L.C. v. Fed. Ins. Co., 83 F.4th 405,
408 (5th Cir. 2023).
Plaintiff must file, no later than April 8, 2026, an amended Diversity Jurisdiction
Disclosure Statement that clarifies whether Manojkumar Patel is its sole member. If he is
not, the statement must set forth all of Plaintiff's members and their citizenship.
THUS DONE AND SIGNED in Shreveport, Louisiana, this Ist day of April, 2026.
Mark L. Hornsby
U.S. Magistrate Judge
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