Young v. Century House Historical Society
2000 WL 1535939, 2000 U.S. Dist. LEXIS 15229, 117 F. Supp. 2d 277 (2000)
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Rule of Law:
For purposes of diversity jurisdiction, a party's domicile is determined by their physical presence in a state combined with an intent to remain there indefinitely, which is assessed by examining the totality of objective evidence, such as voter registration, driver's license, and property ownership, rather than merely where the party spends the majority of their time.
Facts:
- Jeremy Young owned a condominium in Tivoli, New York, had attended college in New York, and his parents resided in New York.
- In April 1998, Young began working for a software company in New Jersey and rented an apartment in Boonton, New Jersey.
- At the time the lawsuit was filed in December 1998, Young split his time between the two residences, spending weekdays in New Jersey and weekends in New York.
- Young was registered to vote in New York, had voted there four times since 1992, held a New York State driver's license, and his vehicle was registered in New York.
- Young's 1998 federal income tax return listed his taxpayer address as Tivoli, New York.
- On August 8, 1998, Young was injured when he fell into a kiln on property in New York owned by Century House Historical Society after attending a concert there.
- After his injury, Young provided his New York address to hospitals in both New York and New Jersey.
Procedural Posture:
- Jeremy Young filed a negligence lawsuit against Century House Historical Society and other defendants in the U.S. District Court for the Northern District of New York, asserting diversity jurisdiction.
- The defendants filed cross-claims against one another.
- Defendant Century House Historical Society moved for summary judgment, which the court denied.
- Subsequently, Century House filed a motion to dismiss for lack of subject matter jurisdiction, arguing that complete diversity of citizenship was absent because the plaintiff was domiciled in New York.
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Issue:
Does federal diversity jurisdiction exist in a negligence action where the plaintiff maintains residences in both New York and New Jersey, but his key objective indicators of domicile—such as owning property, voter registration, driver's license, and tax filings—remain in New York, the same state as a defendant?
Opinions:
Majority - Hurd, District Judge
No, federal diversity jurisdiction does not exist because the plaintiff failed to prove he changed his domicile from New York to New Jersey. A party's domicile is established by physical presence and an intent to remain, evaluated through the totality of objective evidence. Although Young spent a majority of his time in New Jersey for work, this was insufficient to establish a new domicile. The court found that the most significant objective indicators—including his property ownership, active voter registration, driver's license, vehicle registration, and the address on his tax returns—all pointed to New York. The burden was on Young to prove he intended to change his domicile, and his failure to update these formal ties demonstrated a lack of intent to permanently remain in New Jersey, thus destroying complete diversity with the New York-domiciled defendants.
Analysis:
This case serves as a clear illustration of the multi-factor test used to determine a party's domicile for diversity jurisdiction purposes. It establishes that subjective intent to change domicile is insufficient; it must be supported by objective evidence. The court's reasoning emphasizes that formal, official connections to a state (like voting, licenses, and taxes) often carry more weight than the mere amount of time spent in a new location for employment. This precedent reinforces the principle that a person can have multiple residences but only one domicile, making it more difficult for litigants to manufacture diversity jurisdiction simply by renting an apartment across state lines.
