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Negligence: Premises Liability-Identification of Doe Defendant-Remand

Staff Report//July 9, 2026//

Negligence: Premises Liability-Identification of Doe Defendant-Remand

Staff Report//July 9, 2026//

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Defendants moved to dismiss plaintiff’s complaint, while plaintiff cross-moved to remand to state court. Plaintiff filed a premises liability action, alleging that she was injured when one of defendant’s employees rushed out of a bathroom door, striking and injuring her knee with the door. After extended proceedings, the court permitted plaintiff to amend her complaint to identify the John Doe employee as a defendant, who was a Missouri resident.

Where plaintiff ultimately followed the court’s order to file an amended complaint and defendant failed to object to the substantive additions, the court ruled that remand was necessary due to the addition of a non-diverse party.

Defendants’ motion to dismiss denied, plaintiff’s motion for remand granted.

Sorrells v. Harrah’s North Kansas City, LLC (MLW No. 84908/Case No. 4:25-cv-00799-RK – 8 pages) (U.S. District Court, Western District of Missouri, Ketchmark, J.)

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