Scotuscast

On March 7, 2016, the Supreme Court decided Americold Realty Trust v. ConAgra Foods, a case giving rise to a dispute over the scope of federal courts’ diversity jurisdiction. A group of corporations whose food perished in a warehouse fire sued the warehouse owner, currently known as Americold Realty Trust, in Kansas state court. Americold then removed the suit to the U.S. District Court for the District of Kansas, which accepted jurisdiction and resolved the dispute in favor of Americold. On appeal, however, the U.S. Court of Appeals for the Tenth Circuit held that the district court had lacked jurisdiction. Although the parties argued that diversity jurisdiction existed because the suit involved citizens of different states, the Tenth Circuit disagreed. As a trust and not a corporation, the court reasoned, Americold’s citizenship depended on that of its members, including shareholders. Given the lack of evidence regarding the shareholders’ citizenship, the court held, the parties had failed to demonstrate t