Americold Realty Trust v. Conagra Foods, Inc.

577 U.S. 378 (2016)

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Nature of the Case

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Facts

Conagra (Ps) stored food in D’s warehouse. Their food perished in a 1991 fire. Ps sued D filing their latest suit in Kansas. D removed the suit to the Federal District Court based on diversity. The District Court accepted jurisdiction and resolved the dispute in favor of D. Ps appealed. The Tenth Circuit disagreed. The court considered the corporate plaintiffs citizens of the States where they were chartered and had their principal places of business. The court applied a different test to determine D’s citizenship because D is a “real estate investment trust,” not a corporation. It held from precedent that the citizenship of any “non-corporate artificial entity” is determined by considering all of the entity’s “members,” which include, at minimum, its shareholders. There was no record of the citizenship of D’s shareholders, the court concluded that the parties failed to demonstrate that Ps were “citizens of different States” than Ds. D appealed.