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United Steelworkers of America, AFL-CIO v. R. H. Bouligny, Inc.
United States Supreme Court
382 U.S. 145 (1965)
R. H. Bouligny, Inc. (Bouligny) (plaintiff), a North Carolina corporation, brought a defamation action against the United Steelworkers of America labor union (the union) (defendant) in North Carolina state court. The union removed the case to federal district court, asserting that the federal court had diversity jurisdiction because the union, an unincorporated association with a principal place of business in Pennsylvania, was a Pennsylvania citizen. Bouligny sought remand to state court, asserting that diversity jurisdiction was improper because an unincorporated association’s citizenship is the citizenship of each of its members, and some of the union’s members were North Carolina citizens. The district court rejected Bouligny’s argument and retained jurisdiction, holding that the union should be treated like a corporation, i.e., as a citizen of the state in which its principal office was located. However, the court of appeals reversed and directed that the case be remanded to state court. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Fortas, J.)
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