Question I had two parts. The first part revolved heavily around the issue of Anna's domicile, and there were lots of facts pointing, variously, to Florida, Massachusetts, and Maryland as her domicile. Students generally handled these facts well. The significance of domicile here, of course, was the need to establish diversity jurisdiction as the basis for removal. Students generally saw the need to note Exxon' s citizenship, and the possibility of a lack of diversity between Anna (maybe a Floridian, maybe not) and Exxon (definitely a citizen of Delaware and Florida). If she is a Floridian, of course, there is not only a failure of diversity. It would also mean she was being sued in her home state court and would therefore be ineligible for removal on that ground as well. A tidy answer might also note that the removal was to the proper federal district court.

Organization

Domicile and Diversity

The issue here is Diversity since Anna wants to remove the state court case to the Florida Federal District. To do so she must establish complete Diversity of all parties.

The problem is that if she is domiciled in Florida then diversity does not exist with Exxon since it can either be a citizen of the state of incorporation - Delaware, or of its principle place of business - Florida, and if it is Florida, and if Anna is domiciled in Florida, then no complete diversity, and thus Anna cannot remove to any of the 3 Federal District courts mentioned, Central, Northern or Southern.