JPMorgan Chase Bank v. Traffic Stream (BVI) Infrastructure Limited
United States Supreme Court
536 U.S. 88 (2002)

- Written by Catherine Cotovsky, JD
Facts
JPMorgan Chase Bank (Chase) (plaintiff) sued Traffic Stream (BVI) Infrastructure Limited (Traffic Stream) (defendant) in federal district court for breach of a contract to build and operate toll roads in China. Traffic Stream was incorporated under the laws of the British Virgin Islands, which was not recognized by the United States as an independent foreign state because it was an overseas territory of the United Kingdom. Nonetheless, the district court found that it had subject-matter jurisdiction by virtue of alienage diversity between Chase and Traffic Stream, and Chase was granted summary judgment. Traffic Stream appealed, and the United States Court of Appeals for the Second Circuit reversed the district court on the grounds that Traffic Stream was a citizen of a territory and thus not a citizen or subject of a foreign state that would establish alienage diversity jurisdiction. The Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Souter, J.)
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