Alliance for Water Efficiency v. Fryer, No. 14 C 115, Slip Op. (N.D. Ill. Jan. 15, 2014) (Shadur, Sen. J.).

Judge Shadur sua sponte ordered plaintiff Alliance for Water Efficiency (“AWE”) to correct two deficiencies in its diversity jurisdiction pleading:

  1. AWE pled that it was headquartered in Illinois, but did not plead its corporate citizenship.
  2. AWE pled that defendant was a resident of California, but not whether defendant was also a citizen of California.

Although the Seventh Circuit generally required dismissing complaints where an individual’s residence, but not citizenship, is pled the Court found that “Draconian” and afforded AWE five days to correct its complaint, if it could.