By: Derek Hawkins//March 16, 2016//
US SUPREME COURT
Case Name: Americold Realty Trust v. ConAgra Foods, Inc.
Case No.: 14-1382
Focus: Diversity Citizenship
Citizenship for appellants, for purposes of diversity jurisdiction, are based on the citizenship of its members & shareholders.
Historically, the relevant citizens for jurisdictional purposes in a suit involving a “mere legal entity” were that entity’s “members,” or the “real persons who come into court” in the entity’s name. Bank of United States v. Deveaux, 5 Cranch 61, 86, 91. But for the limited exception of jurisdictional citizenship for corporations, see Louisville, C. & C. R. Co. v. Letson, 2 How. 497, 558, this Court continues to “adhere to [the] oft-repeated rule that diversity jurisdiction in a suit by or against the entity depends on the citizenship of ‘all [its] members,’ ” Carden v. Arkoma Associates, 494 U. S. 185, 195. Applying the rule here, Americold possesses the citizenship of all its members, who, under Maryland law, include its shareholders. See, e.g., Md. Corp. & Assns. Code Ann. §8–101(c).
Affirmed