Hearts With Haiti, Inc. v. Kendrick

Federal subject-matter jurisdiction over this dispute involving claims of defamation and other causes of action was premised on a diversity of citizenship. Hearts With Haiti Inc. and Michael Geilenfeld sued Paul Kendrick. Although a jury found for the plaintiffs, the First Circuit remanded the case to address the question of whether federal subject-matter jurisdiction was lacking. The district court dismissed the action for lack of subject matter jurisdiction because Geilenfeld was domiciled in Haiti and thus was not a citizen of a state for the purposes of diversity jurisdiction. The First Circuit affirmed, holding (1) as a stateless American citizen domiciled abroad, Geilenfeld did not satisfy the requirements of diversity jurisdiction; and (2) the district court did not abuse its discretion in refusing to cure the jurisdictional defect by dismissing Geilenfeld from the action. View "Hearts With Haiti, Inc. v. Kendrick" on Justia Law