Grupo Dataflux v. Atlas Global Group, L.P.
United States Supreme Court
541 U.S. 567, 124 S.Ct. 1920, 158 L.Ed.2d 866 (2004)
- Written by Denise McGimsey, JD
Facts
Atlas Global Group, L.P. (Atlas) (plaintiff), a limited partnership formed under Texas law, brought a lawsuit in federal court against Grupo Dataflux (Dataflux) (defendant), a Mexican corporation, alleging breach of contract and quantum meruit claims. Jurisdiction in the federal court was founded on diversity of citizenship. The matter went to trial, and a jury awarded Atlas $750,000 in damages. After trial, but before entry of the judgment, Dataflux moved to dismiss the lawsuit on the ground that the court lacked subject matter jurisdiction. The citizenship of a limited partnership is based on the citizenships of its partners. It was revealed that, at the time of filing, Atlas’s partners were citizens of Delaware, Texas, and Mexico. Thus, aliens on each side of the case precluded diversity jurisdiction under 28 U.S.C. § 1332. The district court dismissed the case. On appeal, Atlas established that its Mexican partners had left the partnership one month prior to trial. Thus, diversity existed at the time of the jury’s verdict. The Fifth Circuit reversed, citing Caterpillar Inc. v. Lewis, 519 U.S. 61 (1996). Dataflux petitioned the United States Supreme Court for certiorari.
Rule of Law
Issue
Holding and Reasoning (Scalia, J.)
Dissent (Ginsburg, J.)
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