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Mraz v. JPMorgan Chase Bank N.A.

Despite Lack of Diversity, Suit's Remand Denied Under Fraudulent Joinder Doctrine

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MEMORANDUM AND ORDER Plaintiffs Camilla Mraz and Jiri (“George”) O. Mraz (“Plaintiffs”) initially brought this action — alleging breach of contract, negligence, breach of fiduciary duty, and breach of the duty of good faith and fair dealing — in New York Supreme Court, in Queens County, against JPMorgan Chase Bank, N.A. (“Chase”), and three Chase employees: Sabrina Nguyen, Jorge Luis Argudo, and Rubiel Tineo. ECF No. 1-2 at 3-9 (“Compl.”). Defendants immediately removed the case to federal court on the basis of diversity jurisdiction. ECF No. 1. Before the Court now is Plaintiffs’ motion to remand the case to state court, ECF No. 13, which they filed concurrently with an amended complaint, ECF No. 14 (“Am. Compl.”). The amended complaint terminates Nguyen as a defendant, seeks to join J.P. Morgan Securities, LLC (“JPMS”) as a defendant, and adds a cause of action for tortious interference with contractual relations. Am. Compl. As pled, complete diversity does not exist: Argudo and Tineo (the “Individual Defendants”) are, like Plaintiffs, citizens of New York, and so too is JPMS. But Chase, JPMS, and the Individual Defendants (together, “Defendants”) argue that, in deciding this motion, the Court should (i) disregard the Individual Defendants, under the doctrine of fraudulent joinder, and (ii) disallow the post-removal joinder of JPMS, under 28 U.S.C. §1447(e). The Court agrees, for the reasons discussed below, and therefore Plaintiffs’ motion is DENIED.BACKGROUNDPlaintiffs Camilla and George Mraz are a married couple residing in Woodside, Queens. See Compl.

1-2; Am. Compl.

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