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Americold Realty Trust v. ConAgra Foods, Inc.
United States Supreme Court
577 U.S. 378, 136 S. Ct. 1012, 194 L. Ed. 2d 71 (2016)
A group of corporations that manufactured food products (collectively, the plaintiff corporations) (plaintiffs) stored products in an underground warehouse owned by Americold Realty Trust (Americold) (defendant). After a warehouse fire destroyed products owned by the plaintiff corporations, the plaintiff corporations filed a lawsuit against Americold in Kansas state court alleging violations of state contract law. The plaintiff corporations were citizens of Delaware, Nebraska, and Illinois. Americold, a real estate investment trust, was organized under Maryland law. Americold removed the case to federal district court on diversity-jurisdiction grounds. The district court ruled in favor of Americold. The plaintiff corporations appealed. The court of appeals held that the district court’s exercise of jurisdiction over the case was improper because diversity of citizenship did not exist between Americold and the plaintiff corporations. The court of appeals reasoned that the citizenship of Americold, a noncorporate legal entity, depended on the citizenship of its members—meaning, in this case, its shareholders. Because no evidence of the citizenship of its shareholders was presented, Americold had failed to show that diversity of citizenship existed. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Sotomayor, J.)
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