Supreme Court Decision Alert - March 7, 2016

Today, the Supreme Court issued one decision, described below, of interest to the business community.

Federal Diversity Jurisdiction—Citizenship of Unincorporated Entities

Americold Realty Trust v. ConAgra Foods, Inc., No. 14-1382

Today, the Supreme Court held that, for purposes of diversity jurisdiction, an unincorporated legal entity has the citizenship of its members (including its shareholders)—even if the entity is labeled a "trust."

Federal courts have jurisdiction over controversies between "citizens" of different States. 28 U.S.C. § 1332(a)(1). For purposes of diversity jurisdiction, a corporation is considered a citizen of the State in which it is incorporated and the State in which its principal place of business is located. 28 U.S.C. § 1332(c). The Supreme Court has long held that an unincorporated legal entity, such as a joint-stock company or a legal partnership, is a citizen of every State in which any of its members are citizens. Carden