Lament for an Evergreen

Storey Mountain LLC v. JP Morgan Chase laments: “Despite the long line of cases requiring parties to establish the citizenship of an LLC’s members, this remains ‘an evergreen problem in our circuit.'”

The Court thus remanded for further development of the record about the parties’ citizenship, reminding that the following was not sufficient to establish diversity jurisdiction as to an LLC: “Storey Mountain LLC ‘is a limited liability company organized under the laws of Wyoming, with its principal place of business in Florida. For purposes of diversity, Garnishor is a citizen of Wyoming and Florida.” No. 24-20535 (Nov. 10, 2025).