Background
Julie Schulz Halbower, as trustee of the Halbower Legacy Trust, sued Hiscox Syndicate 33 of Lloyd’s of London for breach of contract after the insurer denied coverage for two art pieces lost in a fire. The district court dismissed the action for lack of merit, but the Sixth Circuit focused on the threshold issue of jurisdiction.
The court’s reasoning
The court held that even in the absence of a jurisdictional challenge from the parties, it has an independent obligation to ensure diversity jurisdiction exists. The court determined that the parties did not adequately plead facts necessary to establish complete diversity under 28 U.S.C. Section 1332(a)(2).
Because the parties did not adequately plead facts necessary to establish diversity jurisdiction, we remand the case to the district court to conduct further jurisdictional discovery.
Halbower v. Hiscox Syndicate 33 of Lloyd’s of London, No. 25-1152 (6th Cir. 2026)
What it means going forward
The case returns to the district court where the parties must provide additional evidence to prove diversity jurisdiction before the court can address the underlying insurance coverage dispute.
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