The opinion
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
MONICA BRADY CIVIL ACTION
VERSUS NO. 22-799
FEDNAT INSURANCE COMPANY SECTION: “P” (4)
ORDER AND REASONS
Before the Court is the Motion to Remand for Lack of Subject Matter Jurisdiction filed by
Plaintiff Monica Brady.1 The basis of Brady’s motion is that the parties in this case, which was
removed to this Court solely on the basis of diversity jurisdiction, are no longer diverse after the
Louisiana Insurance Guaranty Association (“LIGA”) was added as a defendant.2 The Court
agrees.
Title 28, United States Code, Section 1332 gives federal courts subject matter jurisdiction
over a matter when the parties are completely diverse and the amount in controversy exceeds
$75,000 exclusive of interest and costs.3 These requirements are not met in this case. Brady
alleges in her Amended Complaint that she is a citizen of Louisiana, and it is well established that
LIGA is a citizen of Louisiana for diversity purposes.4 Because complete diversity is lacking,
remand to state court is appropriate.5
1 R. Doc. 33.
2 Brady’s motion is set for submission on April 16, 2025. Local Rule 7.5 of the United States District Court for the
Eastern District of Louisiana requires that a memorandum in opposition to a motion be filed no later than eight days
before the noticed submission date, making the deadline in this instance April 8, 2025. No opposition was filed.
3 28 U.S.C. § 1332.
4 LIGA, as an unincorporated association “has the citizenship for diversity purposes of each of its constituent member
insurers.” Temple Drilling Co. v. La. Ins. Guar. Ass’n, 946 F.2d 390, 394 (5th Cir. 1991). Centauri National Insurance
Company, one of LIGA’s constituent member insurers, is a citizen of Louisiana, and, therefore, LIGA is a citizen of
Louisiana for diversity purposes. See Soza v. S. Fid. Ins. Co., No. 22-1400, 2023 WL 2770125, at *5 (E.D. La. Apr.
4, 2023) (Vitter, J.); Andry v. United Prop. & Cas. Ins., No. 2:22-04544, 2023 WL 6442866, at *1 (E.D. La. Oct. 3,
2023) (Fallon, J.); McDonald v. United Prop. & Cas. Ins. Co., No. 22-3757, 2023 WL 6464772, at *2 (E.D. La. Oct.
4, 2023) (Morgan, J.); 14th St. Properties, LLC v. S. Fid. Ins. Co., No. 22-1593, 2023 WL 416317, at *1 (E.D. La.
Jan. 26, 2023) (Brown, C.J.); Keiffer v. S. Fid. Ins. Co., No. 22-863, 2023 WL 157631, at *1 n.3 (E.D. La. Jan. 11,
2023) (Ashe, J.).
5 See 28 U.S.C. § 1447(e).
Accordingly, IT IS ORDERED that Plaintiff Monica Brady’s Motion to Remand (R. Doc.
33) is GRANTED.
IT IS FURTHER ORDERED that this matter is REMANDED to the 32nd Judicial
District Court for the Parish of Terrebonne, State of Louisiana.
New Orleans, Louisiana, this 10th day of April 2025.
DARRELGAMES PAPILLION
UNITED STATES DISTRICT JUDGE