Facts
- Courtney McBride developed a rare, serious skin disease after receiving treatment at a county hospital.
- McBride filed suit in the United States District Court for the Middle District of Alabama against her treating physician, Dinesh Karumanchi, M.D.; the Houston County Health Care Authority; and other defendants.
- McBride asserted multiple theories of liability, including Alabama medical-malpractice claims, and alleged federal subject-matter jurisdiction under diversity of citizenship (28 U.S.C. § 1332), federal-question jurisdiction (28 U.S.C. § 1331), and supplemental jurisdiction (28 U.S.C. § 1367).
- Over time, the district court granted summary judgment for several defendants and dismissed the Houston County Health Care Authority, leaving Dr. Karumanchi as the remaining defendant as the case approached trial.
- Dr. Karumanchi then challenged diversity jurisdiction, arguing that McBride was domiciled in Alabama when she filed the complaint, which would defeat complete diversity because at least one defendant named at filing was also an Alabama citizen.
- McBride contended she was domiciled in Florida when she filed suit.
- The court ordered jurisdictional briefing and held an evidentiary hearing to decide McBride’s domicile at the time of filing.
Issues
- Whether McBride was domiciled in Florida or Alabama when she filed suit for purposes of diversity jurisdiction under 28 U.S.C. § 1332.
- If McBride was domiciled in Alabama at filing, whether complete diversity was absent because an Alabama defendant was a party when the action commenced, even if that defendant was later dismissed.
Decision
- The court found that McBride was domiciled in Alabama when she filed the lawsuit.
- Because McBride and at least one defendant named at the time of filing were Alabama citizens, complete diversity was lacking at the start of the case and § 1332 could not supply subject-matter jurisdiction.
- The court explained that later case developments (including dismissal of nondiverse defendants) do not cure a lack of complete diversity that existed when the complaint was filed.
Legal Principles
- Citizenship for purposes of § 1332 is determined by domicile, not mere residence.
- Domicile requires both (1) physical presence in a state and (2) intent to remain there for an indefinite period.
- A person’s existing domicile is presumed to continue until a new domicile is established.
- The party invoking diversity jurisdiction bears the burden to prove diversity by a preponderance of the evidence.
- Complete diversity is evaluated based on the parties’ citizenship at the time the action is filed; post-filing events generally do not create diversity jurisdiction if it was missing at filing.
- A district court may resolve disputed jurisdictional facts through evidence and an evidentiary hearing.
Conclusion
In McBride v. Karumanchi, the court resolved a jurisdictional dispute about McBride’s domicile and held that she was an Alabama citizen when she filed suit, defeating complete diversity because an Alabama defendant was also a party at filing; as a result, the court could not rely on 28 U.S.C. § 1332 as a basis for subject-matter jurisdiction.