| Americold Realty Trust v. ConAgra Foods, Inc. | |
|---|---|
 | |
| Argued January 19, 2016 Decided March 7, 2016 | |
| Full case name | Americold Realty Trust, Petitioner v. ConAgra Foods, Inc., et al. |
| Docket no. | 14–1382 |
| Citations | 577 U.S. ___ (more) 136 S. Ct. 1012; 194 L. Ed. 2d 71 |
| Opinion announcement | Opinion announcement |
| Case history | |
| Prior | ConAgra Foods, Inc. v. Americold Logistics, LLC, 776 F.3d 1175 (10th Cir. 2015); cert. granted, 136 S. Ct. 27 (2015). |
| Holding | |
| For the purposes of diversity jurisdiction, the citizenship of a real estate investment trust should be determined by the citizenship of its shareholders when the real estate investment trust is "held and managed for the benefit and profit of any person who may become a shareholder" | |
| Court membership | |
| |
| Case opinion | |
| Majority | Sotomayor, joined by unanimous |
| Laws applied | |
| 28 U.S.C. § 1332 | |
Americold Realty Trust v. ConAgra Foods, Inc., 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified rules for determining whether a federal court may exercise diversity jurisdiction in cases involving unincorporated organizations.[1] The case began as a contract dispute between food producers and a warehouse owner when millions of tons of stored food were destroyed in a warehouse fire.[2] A federal trial court initially ruled in favor of the warehouse owner, but on appeal, the United States Court of Appeals for the Tenth Circuit ruled that the federal district court may not have had jurisdiction.[3] The Tenth Circuit held that the warehouse owner, a real estate investment trust ("REIT"), should be treated as an unincorporated organization and the district court should not be allowed to exercise diversity jurisdiction without examining the citizenship of the members of the real estate investment trust.[3] The warehouse owner appealed to the Supreme Court, which granted certiorari to resolve a circuit split "regarding the citizenship of unincorporated entities."[3]
Writing for a unanimous Court, Justice Sonia Sotomayor held that for the purposes of diversity jurisdiction, the citizenship of a real estate investment trust should be determined by the citizenship of its shareholders when the real estate investment trust is "held and managed for the benefit and profit of any person who may become a shareholder".[4] Although some commentators have suggested that the Court's ruling is "unlikely to have any broad or long-term impact",[5] others have stated that the Court's ruling "means that REITs like Americold will have a much harder time getting (or keeping) their cases in federal court."[6]
- ^ Americold Realty Trust v. ConAgra Foods, Inc., No. 14–1382, 577 U.S. ___, slip op. at 1, 4 (2016) (internal quotations omitted).
- ^ Americold, slip op. at 1; Amy Howe, Trusts and citizenship: It is an easy question for the Court, Howe on the Court (Mar. 7, 2016) (noting that "millions of tons" of food were destroyed).
- ^ a b c Americold, slip op. at 2.
- ^ Americold, slip op. at 1–4, 6 (internal quotations omitted).
- ^ Ronald Mann, Opinion analysis: Justices choose bright-line rule limiting diversity jurisdiction over business trusts, SCOTUSblog (Mar. 7, 2016).
- ^ Amy Howe, Trusts and citizenship: It is an easy question for the Court, Howe on the Court (Mar. 7, 2016).
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