Reported / Citable
Background
Ayesha S. Islam, proceeding pro se, sued Target L’Oreal for personal injuries allegedly caused by a skin-care product. She sought $400,000 in damages and invoked both federal-question and diversity jurisdiction.
Islam alleged that she is a Texas citizen and provided an Austin, Texas address for Target L’Oreal. But her complaint did not identify the defendant’s state of incorporation or principal place of business.
The Court’s Holding
Magistrate Judge Susan Hightower held that the complaint did not establish federal-question jurisdiction because it alleged only a personal-injury claim and did not identify any basis under federal law.
The court also could not determine whether diversity jurisdiction existed. Although Islam alleged an amount in controversy exceeding $75,000, she had not pleaded the corporate citizenship facts necessary to assess complete diversity. The court ordered her to file, by September 4, 2026, a statement alleging Target L’Oreal’s principal place of business and state of incorporation as of the complaint’s filing date.
Key Takeaways
- A personal-injury allegation alone does not establish federal-question jurisdiction.
- A corporation’s citizenship requires pleading both its state of incorporation and principal place of business.
- Failure to comply with the order may result in dismissal for want of prosecution and failure to obey a court order under Rule 41(b).
Why It Matters
The order illustrates the federal court’s independent duty to confirm subject-matter jurisdiction, including in pro se cases. A plaintiff relying on diversity must plead sufficient facts to show complete diversity, not merely an address for a corporate defendant.