Unreported / Non-Citable
Background
Harold J. Rucker, Jr., representing himself, sued CSAA Insurance Exchange and other defendants in the Eastern District of California. According to his Second Amended Complaint (ECF No. 13), which the magistrate judge accepted as the operative pleading, he was injured in a motor vehicle collision on April 12, 2018, and held an Uninsured Motorist policy with $500,000 in coverage containing an arbitration provision. He alleges that CSAA could not complete arbitration before a state-court-ordered deadline, thereby waiving its right to arbitrate, and that CSAA unlawfully tried to make him sign a release before making any partial settlement payment. These are allegations, not findings.
The complaint pleads seven causes of action, each under California law: breach of contract, violation of Insurance Code sections 11582.2(h) and 790.03, breach of the implied covenant of good faith and fair dealing, void contract, violation of Civil Code section 3294, and punitive damages. Rucker asserts that both federal-question and diversity jurisdiction exist. The procedural history is unusual. An October 2025 show-cause order asked why the case should not be dismissed under the Rooker-Feldman doctrine. Rucker responded with objections and amended complaints, sought a default that the Clerk declined, and then filed a notice of voluntary dismissal, after which the case was closed. On May 20, 2026, he moved for relief from judgment. The magistrate judge recommended granting that motion, and the district judge adopted the recommendation, reopening the case.
The Court’s Holding
This is an order to show cause, not a dismissal or final judgment. Magistrate Judge Allison Claire concluded that, on the allegations pleaded, neither basis for federal jurisdiction is available, and directed Rucker to explain in writing within 14 days why the court has subject matter jurisdiction. On diversity, the order notes that under 28 U.S.C. section 1332 a corporation is a citizen of both its state of incorporation and the state of its principal place of business. Rucker alleges that he is a California citizen and that CSAA is a Delaware corporation with its principal place of business in California. On those allegations the parties are not diverse.
On federal question, the order applies the well-pleaded complaint rule, under which federal jurisdiction exists only when a federal question appears on the face of the properly pleaded complaint. A case arises under federal law where federal law creates the cause of action or where vindication of a state-law right necessarily turns on some construction of federal law. Rucker relies on California Insurance Code and Civil Code provisions and says the United States is a necessary and indispensable party to enforce those rights. The court called that incorrect as a matter of law, noting that he invokes no federal statute or constitutional provision and that the United States is not a necessary party to adjudication of California law.
If Rucker does not respond on time, the court stated that it will recommend dismissal without prejudice for lack of subject matter jurisdiction. That would be a recommendation to the district judge rather than an automatic dismissal, and no merits ruling has been made on the insurance claims.
Key Takeaways
- A corporation is a citizen of both its state of incorporation and its principal place of business, so a California plaintiff who alleges the insurer's principal place of business is in California cannot rely on diversity jurisdiction.
- Under the well-pleaded complaint rule, a federal question must appear on the face of the complaint; listing only California statutory and common-law claims does not create federal-question jurisdiction.
- Asserting that the United States is a necessary and indispensable party to enforce state statutes does not convert state-law claims into federal ones.
- The order is a directive to respond within 14 days, not a dismissal; any dismissal for lack of jurisdiction would be recommended without prejudice.
- The order is not a published decision and carries no precedential weight; it reflects a routine application of settled jurisdictional rules.
Why It Matters
The order shows a court examining its own subject matter jurisdiction at the outset of a reopened case, even though the plaintiff had already filed several pleadings and the case had been closed and revived. It places the burden on a self-represented plaintiff to identify a genuine jurisdictional basis, and it signals that the previously raised Rooker-Feldman concern is not the ground of this order.
For disputes over uninsured motorist coverage and insurer conduct, the order is a reminder that claims pleaded solely under California law generally belong in state court when the plaintiff and a defendant insurer are both California citizens. What remains open is Rucker's response, any recommendation on dismissal, and the district judge's ruling; nothing here resolves the underlying coverage or arbitration dispute.