Diversity jurisdiction in a suit involving a non-corporate artificial entity depends on the citizenship of all its members.
After a warehouse fire, a group of corporations sued the warehouse owner, a real estate investment trust, in state court. The owner removed the case to federal court, but the court of appeals held that diversity jurisdiction was lacking because the owner's citizenship could not be determined. The Supreme Court addresses whether an unincorporated entity, such as a real estate investment trust, possesses the citizenship of its members for diversity purposes. The Court holds that while humans and corporations can assert their own citizenship, other unincorporated entities take the citizenship of all their members. Because the trust is an unincorporated business entity under state law, its members include its shareholders.
577 U.S. at 381 Determining citizenship of unincorporated entities for diversity jurisdiction174 citing casesnoting that because trusts bring or defend legal proceedings in their own name, courts look at citizenship of a trust’s trustees for purpose of diversity jurisdiction
- Watt, No. 1:26-cv-00637 (N.D. Ill. Sept. 4, 2026). (Despite our oft-repetition of the rule linking unincorporated entities with their ‘members,’ we have never expressly defined the term.)
- Brown, No. 1:21-cv-00198 (D.R.I. May 21, 2026). (with reference to specific States’ laws, we have identified the members of a joint-stock company as its shareholders, the members of a partnership as its partners, the members of a union as the workers affiliated with…)
- Martinez v. KLLM Transp. Servs., LLC, No. 3:24-cv-00412 (M.D. La. Feb. 27, 2025). Mar. 27, 2018). 50 See, Americold, 577 U.S. at 382 (“This case asks us to determine the citizenship of Americold Realty Trust, a ‘real estate investment trust’ organized under Maryland law.
- Benjamin v. Ollie's Bargain Outlet, Inc., No. 1:24-cv-00683 (N.D.N.Y. Dec. 9, 2024).(In general, the citizenship of a limited liability company is determined by the citizenship of each of its members.)
- Foster v. United Servs. Auto. Ass'n, No. 4:24-cv-00021 (E.D. Ark. July 10, 2024).([I]n a reciprocal insurance association[,] the members, by exchanging contracts of insurance, are both the insurers and the insureds.)
- Hutten v. Specialized Loan Servicing LLC, No. 2:23-cv-00031 (E.D.N.C. Oct. 17, 2023).(For these unincorporated entities, we too have adhered to our oft-repeated rule that diversity jurisdiction in a suit by or against the entity depends on the citizenship of all its members.)
- Karpel v. Gebrueder Knauf Verwaltungsgesellschaft, KG, No. 1:21-cv-24168 (S.D. Fla. June 6, 2023). Again, while it very well may be that the owners are also the partners, [the Plaintiff] must make that clear.”); see also Americold Realty Tr. v. ConAgra Foods, Inc., 577 U.S. 378, 381-82 , 136 S. Ct. 1012, 1015 (2016) (“[W]e have identifi…
- Harley v. Isael Gonzalez, No. 4:21-cv-00065 (S.D. Ga. July 29, 2021).(diversity jurisdiction in a suit by or against [an unincorporated] entity depends on the citizenship of all of its members)
- Michael Bynane v. The Bank of New York Mellon, et, No. 16-20598 (5th Cir. Aug. 4, 2017).published See Americold, 136 S. Ct. at 1016 (“And when a trustee files a lawsuit or is sued in her own name, her citizenship is all that matters for diversity purposes.”).
- Zoroastrian Ctr. & Darb-E-Mehr v. Rustam Guiv Found., 822 F.3d 739 (4th Cir. 2016).publishedSee Americold, 136 S.Ct. at 1016 (“[Cjonfusion regarding the citizenship of a trust is understandable and widely shared.”).
Show 163 more citing cases
- Halibut Trust v. Floerchinger, No. 4:20-cv-00005 (D. Alaska May 13, 2020). Case No. 4:20-cv-00005-SLG, Halibut Trust v. Floerchinger years after Johnson was decided, in its opinion in Americold Realty Trust v. ConAgra Foods, Inc., the United States Supreme Court drew a distinction between traditional and non-trad…
- Blue Cross & Blue Shield of Alabama v. CVS Pharmacy, Inc., No. 1:20-cv-00236 (D.R.I. Sept. 8, 2026).Courts have extended this rule to all sorts of unincorporated entities, including unions, partnerships, limited partnerships (“LPs”), limited liability companies (“LLCs”), and limited liability partnerships (“LLPs”). , , 577 U.S. 378, 381…
- Wang Ex Rel. Wong v. New Mighty U.S. Trust, 843 F.3d 487 (D.C. Cir. 2016).published
- Equity Trust Co. Custodian v. Windwrap, LLC, No. 1:19-cv-03048 (N.D. Ill. Mar. 26, 2020).
- ADA Carbon Solutions (Red River) v. Atlas Carbon, 146 F.4th 1296 (10th Cir. 2025).published
- RTP LLC v. Orix Real Est. Capital, Inc., 827 F.3d 689 (7th Cir. 2016).published
- Kirschenbaum v. 650 Fifth Avenue & Related Props., No. 14-1963(L) (2d Cir. July 20, 2016).published
- Brian Just. v. Wells Fargo Bank, N.A., No. 15-20615 (5th Cir. Mar. 23, 2017).unpublished
- Raymond Loubier Irrevocable Trust v. Noella Loubier, 858 F.3d 719 (2d Cir. 2017).published
- Doermer v. Oxford Fin. Grp., Ltd., 884 F.3d 643 (7th Cir. 2018).published
- GBForefront LP v. Forefront Mgmt. Grp. LLC, 888 F.3d 29 (3d Cir. 2018).published
- Momentum Eng'g, LLC, James C. Larsen & Fran Larsen v. Lee Laverne Tabler, No. 14-18-00002-CV (Tex. App.—Houston [14th Dist.] Aug. 23, 2018).published
- in Re: Rosewood Private Investments Inc., No. 05-18-00166-CV (Tex. App.—Dallas Sept. 17, 2018).published
- The Bank of New York Mellon v. Thunder Props., Inc., No. 17-16575 (9th Cir. Sept. 25, 2019).unpublished
- C.F. Folks, Ltd. v. McP II Jefferson, LLC, No. 2019-1024 (D.D.C. Dec. 2, 2019).published
- Church Jt. Venture, L.P. v. Earl Blasingame, 947 F.3d 925 (6th Cir. 2020).published
- United States v. Fridman, 974 F.3d 163 (2d Cir. 2020).published
- Navy Fed. Credit Union v. LTD Fin. Servs., LP, 972 F.3d 344 (4th Cir. 2020).published
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- Abrahams v. Simplify Compliance, LLC, No. 2019-3009 (D.D.C. Mar. 30, 2021).published
- Peace Church Risk Retention Gr v. Johnson Controls Fire Protecti, 49 F.4th 866 (3d Cir. 2022).published
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- BRT Mgmt. LLC v. Malden Storage LLC, 68 F.4th 691 (1st Cir. 2023).published
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577 U.S. at 383 Determining citizenship of trusts and unincorporated associations115 citing cases[T]he citizenship of an unincorporated association . . . is determined by the citizenship of each of its members” (emphasis in original)
- Watt, No. 1:26-cv-00637 (N.D. Ill. Sept. 4, 2026). See Americold, 577 U.S. at 381 (“Despite our oft-repetition of the rule linking unincorporated entities with their ‘members,’ we have never expressly defined the term.”).
- Wilmington Sav. Fund Soc'y, FSB, as Owner Tr. of the Residential Credit Opportunities Trust IX-A v. Est. of James E. Lowry; Est. of Wilma M. Lowry; Rebecca Ann Lowry; Unknown Heirs, Devisees, & Legatees of the Est. of James E. Lowry; & Unknown Heirs, Devisees, & Legatees of the Est. of Wilma M. Lowry, No. 1:25-cv-00380 (D.N.M. July 31, 2026).([W]hen a trustee files a lawsuit or is sued in her own name, her citizenship is all that matters for diversity purposes.)
- Barnes, No. 1:25-cv-03773 (S.D.N.Y. June 1, 2026).([T]he citizenship of an unincorporated association . . . is determined by the citizenship of each of its members)
- Global Legends Trust v. JPMorgan Chase Bank, N.A., No. 3:26-cv-00287 (M.D. La. May 15, 2026). (Treating the trust as a non-corporate artificial entity and applying the ‘oft-repeated rule that diversity jurisdiction in a suit by or against the entity depends on the citizenship of all [its] members,’ the Supreme C…)
- Garrity v. Proj. Neptune LLC, No. 2:24-cv-00829 (D. Utah Aug. 18, 2025).(So long as an entity is unincorporated, we apply our oft-repeated rule that it possesses the citizenship of all its members.)
- Martinez v. KLLM Transp. Servs., LLC, No. 3:24-cv-00412 (M.D. La. Feb. 27, 2025). Mar. 27, 2018). 50 See, Americold, 577 U.S. at 382 (“This case asks us to determine the citizenship of Americold Realty Trust, a ‘real estate investment trust’ organized under Maryland law.
- Hayes v. ASCAP (NFPO) (inc), No. 1:24-cv-01883 (S.D.N.Y. Sept. 16, 2024).([T]he citizenship of an unincorporated association . . . is determined by the citizenship of each of its members)
- Princeton Alt. Income Fund, L.P., No. 3:24-cv-03013 (D.S.D. Aug. 16, 2024).(So long as such an entity is unincorporated . . . it possesses the citizenship of all its members.)
- Westbrook v. Caliber Home Loan Inc., No. 2:23-cv-00624 (D. Ariz. May 24, 2023).(Navarro [does not] limit an entity’s 24 membership to its trustees just because the entity happens to call itself a trust.)
- Revitalizing Auto Cmtys. Env't Response Tr. v. Nat'l Grid USA, 10 F.4th 87 (2d Cir. 2021).published(Traditionally, a trust was not considered a distinct 20 legal entity, but a ‘fiduciary relationship’ between multiple people. . . . [L]egal proceedings involving a trust were brought by or against the trustees in their…)
Show 104 more citing cases
- Honig v. Hansen, No. 1:20-cv-05872 (S.D.N.Y. Aug. 9, 2021). P’ship, 213 F.3d 48 , 51052 (2d Cir. 2000) (citing Carden v. Arkoma Assocs., 494 U.S. 185 , 195- 96 (1990)); see also Americold Realty Tr. v. Conagra Foods, Inc., 136 S. Ct. 1012, 1014 (2016) (“While humans and corporations can assert thei…
- Gaines v. AstraZeneca Pharm., No. 1:21-cv-05323 (S.D.N.Y. July 26, 2021).([T]he citizenship of a limited liability company depends upon the citizenship of its members.)
- Stream Fam. Ltd. P'ship v. Targa Midstream Servs. LLC, No. 2:25-cv-01856 (W.D. La. Sept. 15, 2026). Id. (“For a traditional trust, therefore, there is no need to determine its membership, as would be true if the trust, as an entity, were sued.”). 7 The Trust documents contain some indication that Heard has the power to litigate on behalf…
- New York Packaging II, LLC v. Maierhoffer, No. 2:23-cv-00825 (E.D.N.Y. Aug. 4, 2023). A trust’s citizenship turns on “whether the trust is a traditional trust or a business trust.” Bergman, 2019 WL 2257244 , at *16 (citing Americold Realty Tr. v. Conagra Foods, Inc., 577 U.S. 378, 383 (2016)); see also id. (“When state law…
- Hicks v. Heart of Hospice, LLC, No. 4:19-cv-00106 (N.D. Miss. Nov. 22, 2019).Americold Realty Trust v. Conagra Foods, Inc., 135 S. Ct. 1012 , 194 L.Ed. 2d 71 (2016) (“So long as such an entity is unincorporated, we apply our oft-repeated rule that it possesses the citizenship of all its members.
- Arneault v. Diamondhead Casino Corp., 277 F. Supp. 3d 671 (D. Del. 2017).published See Americold Realty Trust v. Conagra Foods, Inc., — U.S. —, 136 S.Ct. 1012, 1016 , 194 L.Ed.2d 71 (2016) (“When a trustee files a lawsuit or is sued in her own name, her citizenship is all that matters for diversity purposes.
- Ranta, No. 2:25-cv-14489 (D.N.J. Sept. 14, 2026).“[t]raditionally, a trust was not considered a distinct legal entity, but a ‘fiduciary relationship’ between multiple people”
- Marco’s Franchising, LLC v. Granular Ins. Co., No. 3:26-cv-00805 (N.D. Ohio Aug. 20, 2026).Americold Realty Tr. v. Conagra Foods, Inc., 577 U.S. 378, 383 (2016).
- Wang Ex Rel. Wong v. New Mighty U.S. Trust, 843 F.3d 487 (D.C. Cir. 2016).published
- Citibank, N.A. v. Najda, No. 1:14-cv-13593 (D. Mass. Sept. 7, 2023).
- ADA Carbon Solutions (Red River) v. Atlas Carbon, 146 F.4th 1296 (10th Cir. 2025).published
- Dolgencorp, LLC v. Werner Enter., Inc., No. 1:19-cv-01019 (S.D. Ala. Nov. 26, 2019).
- Paul Johnson Drywall Inc. v. Sterling Grp. LP, No. 2:21-cv-01408 (D. Ariz. Aug. 20, 2021).
- Capitol Indem. Corp. v. BES Design/Build, LLC, No. 1:18-cv-00537 (S.D. Ala. Feb. 20, 2019).
- Pulse Acquisition Corp. v. Jacksonville Injury Ctr., LLC, No. 3:19-cv-01192, 2020 WL 5526399 (M.D. Fla. Sept. 15, 2020).
- Young v. Figueroa, No. 3:24-cv-00118 (M.D. Fla. Feb. 6, 2024).
- Adams v. Fam. Dollar Stores of Florida LLC, No. 3:24-cv-00119 (M.D. Fla. Feb. 5, 2024).
- Millikin v. The TJX Companies Inc., LLC, No. 3:24-cv-00139 (M.D. Fla. Feb. 9, 2024).
- Roger v. Cooper Technica, Inc., No. 1:18-cv-06744 (N.D. Ill. Nov. 30, 2020).
- King v. Michel, No. 2:19-cv-02277 (D. Kan. Oct. 9, 2019).
- Clancy v. Vacationaire Estates, Inc., No. 0:18-cv-02249 (D. Minn. Feb. 27, 2019).
- Short v. Oros, No. 5:24-cv-00427 (M.D. Fla. Aug. 21, 2024).
- Wurts v. Branch Banking & Trust Co., No. 2:19-cv-00100 (S.D. W. Va. Aug. 26, 2019).
- Redondo Martinez v. Flynt, No. 3:25-cv-00007 (M.D. Fla. Jan. 9, 2025).
- AK Capitol v. Casa Del Sol Spirits, No. 2:25-cv-00011 (D. Utah Feb. 24, 2025).
- Hancock v. Target Corp., No. 3:25-cv-00251 (M.D. Fla. Mar. 13, 2025).
- Repecka v. Walmart Stores East, L.P., No. 3:25-cv-00676 (M.D. Fla. June 23, 2025).
- Snow v. Sumner, No. 3:25-cv-00731 (M.D. Fla. July 7, 2025).
- Jaghab v. Progressive Select Ins. Co., No. 3:25-cv-00743 (M.D. Fla. July 11, 2025).
- Danube Logistics USA, Inc. as assignee of Byd Am., LLC v. Lynnhurst Logistics, LLC, No. 3:25-cv-00923 (M.D. Fla. Aug. 21, 2025).
- Nowak, No. 3:26-cv-01461 (M.D. Fla. June 16, 2026).
- 4900 Morse Land Trust v. Occidental Petroleum Corp., No. 2:23-cv-00040 (N.D. Ind. Feb. 14, 2023).
- Crayne v. The Lincoln Nat'l Life Ins. Co., No. 1:23-cv-00484 (N.D. Ind. Nov. 28, 2023).
- Santiago v. Wal-Mart Stores Texas LLC, No. 4:24-cv-00134 (E.D. Tex. Sept. 6, 2024).
- Beesley v. Brinton, No. 2:17-cv-00735 (D. Utah Feb. 22, 2024).
- Cook v. Marshall, 126 F.4th 1031 (5th Cir. 2025).published
- Townsend, No. 3:25-cv-00445 (N.D. Ind. Oct. 22, 2025).
- Ruiz v. Millennium Square Residential Ass'n, No. 2019-3765, 2022 WL 296200 (D.D.C. Feb. 1, 2022).published
- The Elswick Co., LLC v. U. S. Bancorp Gov't Leasi, No. 20-2171 (4th Cir. June 14, 2022).unpublished
- George Leeson v. U. S. Bancorp Govt Leasing, No. 20-2163 (4th Cir. June 14, 2022).unpublished
- Dianna Nidy v. U.S. Bancorp, No. 19-1759 (4th Cir. June 14, 2022).unpublished
- Constance Arthur-Nelson v. U. S. Bancorp Gov't Leasi, No. 20-2172 (4th Cir. June 14, 2022).unpublished
- Peter Otoh v. Fed. Nat'l Mortg. Ass'n, No. 22-13279 (11th Cir. July 19, 2023).unpublished
- Lopez v. Lopez, No. 84950-COA (Nev. Nov. 30, 2023).published
- Wishengrad v. Carrington Mortg. Servs., 529 P.3d 880 (Nev. 2023).published
- Lopez v. Lopez, 541 P.3d 117 (Nev. 2023).published
- D Stadtler Trust 2015 Trust v. Gorrie, No. 2:22-cv-00314 (D. Ariz. Nov. 29, 2022).
- C&C Props., Inc. v. Shell Pipeline Co., No. 1:14-cv-01889 (E.D. Cal. Sept. 6, 2022).
- CollegeStreet Imp. & Exp. (Tianjin) Co. Ltd. v. XL x HF LLC, No. 3:23-cv-02303 (N.D. Cal. Aug. 10, 2023).
- Powell v. Hilker, No. 1:22-cv-00087 (N.D. Ind. Apr. 4, 2022).
- Powell v. Hilker, No. 1:22-cv-00087 (N.D. Ind. Apr. 28, 2022).
- Elite Med. Staffing LLC v. Landmark Recovery of Carmel LLC, No. 1:23-cv-00396 (N.D. Ind. Sept. 21, 2023).
- MMI of Harford City, LLC v. Auto-Owners Ins. Co., No. 1:24-cv-00084 (N.D. Ind. Feb. 27, 2024).
- Jones v. Landmark Recovery of Louisville, LLC, No. 3:23-cv-01086 (N.D. Ind. Apr. 2, 2024).
- Citibank, N.A. v. Najda, No. 1:14-cv-13593 (D. Mass. Feb. 27, 2023).
- BRT Mgmt. LLC v. Malden Storage LLC, No. 1:17-cv-10005 (D. Mass. Dec. 18, 2023).
- Koester v. Mid Rivers Mall CMBS, LLC, No. 4:23-cv-01306 (E.D. Mo. Jan. 8, 2024).
- Richards Bldg. Servs., LLC v. Hegarty, No. 5:21-cv-00281 (E.D.N.C. Apr. 18, 2022).
- Gray v. Gray, No. 1:22-cv-00560 (D.N.H. May 30, 2023).
- Gaines v. AstraZeneca Pharm., No. 1:21-cv-05323 (S.D.N.Y. Oct. 12, 2021).
- Gaines v. AstraZeneca Pharm., No. 1:21-cv-05323 (S.D.N.Y. Sept. 26, 2022).
- Wells Fargo Bank, Nat'l Ass'n, as Tr., for the benefit of the holders of COMM 2015-LC19 Mortg. Trust Commerical Mortg. Pass-Through Certificates v. 5615 N. LLC, No. 1:20-cv-02048, 2022 WL 15523689 (S.D.N.Y. Oct. 27, 2022).
- Sanders v. New York Times, No. 1:23-cv-02105, 2023 WL 3724818 (S.D.N.Y. May 30, 2023).
- McDowell v. Manhattan Med. Assocs. LLC, No. 1:23-cv-07110 (S.D.N.Y. Nov. 7, 2023).
- Kelley v. Westchester Cnty. Fam. Court, No. 1:23-cv-07519 (S.D.N.Y. Nov. 20, 2023).
- RBX CAPITAL, LP v. Xorax Fam. Trust, No. 2:21-cv-03774 (E.D. Pa. Sept. 28, 2022).
- Citibank, N.A v. Hello Flatbush LLC, No. 1:23-cv-10920 (S.D.N.Y. July 10, 2024).
- Miolan v. Milmar Food Grp., LLC, No. 1:24-cv-06136 (S.D.N.Y. Aug. 15, 2024).
- Mejia v. The Bank of New York Mellon Trust Co., Nat'l Ass'n, No. 7:22-cv-00029 (S.D. Tex. Feb. 22, 2022).
- Parler LLC v. Amazon Web Servs. Inc, No. 2:21-cv-00270 (W.D. Wash. July 1, 2021).
- Maxitransfers LLC v. Envios La Costenita 1 Inc, No. 2:24-cv-01016 (W.D. Wash. Aug. 6, 2024).
- Leist v. Swanson, No. 1:21-cv-01458 (E.D. Wis. Apr. 26, 2022).
- Padron v. Endurance Dealer Servs., No. 5:24-cv-00683 (W.D. Okla. Nov. 7, 2024).
- Harris v. City Nat'l Bank, No. 6:24-cv-00513 (N.D.N.Y. Nov. 15, 2024).
- Wilmington Trust, Nat'l Ass'n v. Aevri Salina Meadows LLC, No. 1:23-cv-08824, 2025 WL 405721 (S.D.N.Y. Feb. 5, 2025).
- Poor v. Lindell, No. CUMbcd-cv-18-27 (Me. Super. Ct May 11, 2023).unpublished
- Davoodi v. Zeta Global Holdings Corp., No. 1:24-cv-08961 (S.D.N.Y. Feb. 26, 2025).
- Cassidy v. Citrus Cnty. Mosquito Control Dist., No. 5:25-cv-00043 (M.D. Fla. Apr. 8, 2025).
- Santos v. Endurance Dealer Servs., LLC, No. 1:25-cv-00401 (D.N.M. Apr. 30, 2025).
- Psalms Creative LLC v. Beacon Inv. Holdings LLC, No. 1:25-cv-02135 (S.D.N.Y. Apr. 30, 2025).
- Wilmington Trust, Nat'l Ass'n v. Kunba, LLC, No. 1:25-cv-01696 (S.D.N.Y. July 9, 2025).
- Hoeppner-Cruz v. Brower, No. 3:24-cv-05170 (N.D. Cal. July 16, 2025).
- Deutsche Bank AG, London Branch v. Finepoint Capital LP, No. 1:24-cv-04567 (S.D.N.Y. July 15, 2025).
- Liveious v. Caesars Ent., Inc, No. 4:24-cv-00145 (S.D. Ind. July 18, 2025).
- Barnes v. Morgan & Morgan, No. 1:25-cv-03773 (S.D.N.Y. July 18, 2025).
- Deutsche Bank Nat'l Trust Co., as Tr. for GSAA Home Equity Trust 2007-5, Asset-Backed Certificates, Series 2007-5 v. Shewtahal, No. 1:24-cv-07892 (E.D.N.Y. Aug. 19, 2025).unpublished
- Greene v. Simpson, No. 0:25-cv-00703 (D. Minn. Aug. 25, 2025).
- Wade v. Newport Grp., Inc., No. 1:22-cv-01126 (W.D. Tenn. Sept. 2, 2025).
- Sherrerd v. Highmark Energy Operating LLC, No. 5:25-cv-00447 (W.D. Okla. Sept. 3, 2025).
- Evan W. Gray v. P Chester L. Gray III, 2023 DNH 067 (D.N.H. 2023).published
- CFSP 2024-AHP1 81-83 Seaman Avenue LLC v. 81 Seaman Realty LLC, Joel Wiener, New York City Env't Control Bd. & “JOHN DOE” NO. 1 THROUGH “JOHN DOE” NO. 100, No. 1:25-cv-04113 (S.D.N.Y. Sept. 9, 2025).
- Weinraub, No. 1:24-cv-03780 (N.D. Ga. July 8, 2026).
- Christian, No. 3:25-cv-00993 (W.D.N.C. July 9, 2026).
- Howard, No. 2:26-cv-04200 (W.D. Mo. Sept. 18, 2026).
- Hometown 2006-1 1925 Valley View, L.L.C. v. Prime Income Asset Mgmt., L.L.C., 847 F.3d 302 (5th Cir. 2017).published
- North Carolina Dept. of Revenue v. Kimberley Rice Kaestner 1992 Fam. Trust, 588 U.S. 262 (2019).published
- SE Prop. Holdings, LLC v. Dyken, No. 1:20-cv-00297 (S.D. Ala. June 14, 2023).
- Alvarado v. LQ 1555 LLC, No. 2:21-cv-00039 (D.N.M. Jan. 29, 2021).
- Silver v. EP Loya Grp., LP, No. 1:23-cv-00448 (D.N.M. Nov. 7, 2023).
- Wilmington Trust, Nat'l Ass'n, As Tr. for the Benefit of the Registered Holders of Benchmark 2018-B5 Mortg. Trust, Commerical Mortg. Pass-Through Certificates, Series 2018-B5 v. 115 Owner LLC, No. 1:20-cv-02157, 2021 WL 5086368 (S.D.N.Y. Nov. 2, 2021).
- Garcia v. Gelco Fleet Trust, No. 3:23-cv-00497 (N.D. Ohio May 8, 2023).
- New Millennium Bldg. Sys. LLC v. Accelerated Constr. & Metal LLC, No. 1:25-cv-00130 (N.D. Ind. Apr. 16, 2025).
- Dome Tech., LLC v. S&J Indus., LLC, No. 1:25-cv-00528 (S.D. Ala. Dec. 18, 2025).
- Jeffrey David Bulkin v. NewRez, LLC et al., No. 2:26-cv-03218 (C.D. Cal. June 15, 2026).
577 U.S. at 382 Determining citizenship of real estate investment trusts37 citing casesThis case asks us to determine the citizenship of Americold Realty Trust, a ‘real estate investment trust’ organized under Maryland law. As Americold is not a corporation, it possesses its members’ citizenship.” (citation omitted)
- Watt, No. 1:26-cv-00637 (N.D. Ill. Sept. 4, 2026). See Americold, 577 U.S. at 381 (“Despite our oft-repetition of the rule linking unincorporated entities with their ‘members,’ we have never expressly defined the term.”).
- Brown, No. 1:21-cv-00198 (D.R.I. May 21, 2026). Id. at 381 (“with reference to specific States’ laws, we have identified the members of a joint-stock company as its shareholders, the members of a partnership as its partners, the members of a union as the workers affiliated with it, and…
- Martinez v. KLLM Transp. Servs., LLC, No. 3:24-cv-00412 (M.D. La. Feb. 27, 2025). (This case asks us to determine the citizenship of Americold Realty Trust, a ‘real estate investment trust’ organized under Maryland law. As Americold is not a corporation, it possesses its members’ citizenship. Nothing…)
- Brian O'Connor v. Fairfax Taxi, Inc., No. 25-1699 (4th Cir. Aug. 19, 2026).publishedAmericold confirmed the point, describing Navarro as a “separate rule” that “coexists” with the all-members rule governing artificial entities. 577 U.S. at 382-83.
- Osk XIV, LLC v. Tdc Blue IV, LLC, No. 1:23-cv-00949 (M.D.N.C. Jan. 23, 2025).
- ADA Carbon Solutions (Red River) v. Atlas Carbon, 146 F.4th 1296 (10th Cir. 2025).published
- Peace Church Risk Retention Gr v. Johnson Controls Fire Protecti, 49 F.4th 866 (3d Cir. 2022).published
- Peter Otoh v. Fed. Nat'l Mortg. Ass'n, No. 23-12302 (11th Cir. Feb. 8, 2024).unpublished
- Rhyne v. MartianCraft, LLC, No. 2:20-cv-00568 (E.D. Va. June 17, 2021).
- Parler LLC v. Amazon Web Servs. Inc, No. 2:21-cv-00270 (W.D. Wash. Sept. 30, 2021).
Show 27 more citing cases
- AK Capitol v. Casa Del Sol Spirits, No. 2:25-cv-00011 (D. Utah Feb. 24, 2025).
- Berkley Nat'l Ins. Co. v. Atl.-Newport Realty LLC, 93 F.4th 543 (1st Cir. 2024).published
- Wilmington Trust, Nat'l Ass'n v. 410 South Main Street LLC, 584 F. Supp. 3d 689 (N.D. Ind. 2022).published
- 4900 Morse Land Trust v. Occidental Petroleum Corp., No. 2:23-cv-00040 (N.D. Ind. Feb. 14, 2023).
- Crayne v. The Lincoln Nat'l Life Ins. Co., No. 1:23-cv-00484 (N.D. Ind. Nov. 28, 2023).
- Main Thirty-Nine Investors, LLC v. Denes, No. 2:21-cv-02246 (D. Kan. Oct. 8, 2021).
- Carr v. IF&P Holding Co., LLC, No. 2:22-cv-00480 (E.D. La. May 16, 2024).
- Oak Plaza, LLC v. Buckingham, No. 8:22-cv-00231, 2022 WL 1591404 (D. Md. May 19, 2022).
- Powell v. Lumen Prop. Mgmt. LLC, No. 1:24-cv-00371 (D. Md. June 18, 2024).
- Senderra Rx Partners LLC v. Express Scripts, Inc., No. 4:21-cv-00521 (E.D. Mo. Aug. 4, 2021).
- Senderra Rx Partners LLC v. Express Scripts, Inc., No. 4:21-cv-00521 (E.D. Mo. Mar. 10, 2022).
- Silva v. Walt Disney World, No. 1:21-cv-00912, 2022 WL 4585811 (M.D.N.C. Sept. 29, 2022).
- MSR Trust v. Nationstar Mortg. LLC, No. 1:21-cv-03089 (S.D.N.Y. Feb. 9, 2022).
- Altruis Grp., LLC v. Prosight Specialty Mgmt. Co., Inc., No. 1:21-cv-10757 (S.D.N.Y. Aug. 10, 2023).
- Fam. Prot. Irrevocable Trust v. Bales, No. 5:22-cv-01039 (W.D. Okla. Dec. 16, 2022).
- Kehrer v. Norfolk S. Ry. Co., No. 3:24-cv-01786 (S.D. Ill. July 30, 2024).
- Santiago v. Wal-Mart Stores Texas LLC, No. 4:24-cv-00134 (E.D. Tex. Sept. 6, 2024).
- Beesley v. Brinton, No. 2:17-cv-00735 (D. Utah Feb. 22, 2024).
- Cook v. Marshall, 126 F.4th 1031 (5th Cir. 2025).published
- Oliver & Co. v. Zamber, No. 4:25-cv-00132 (E.D. Mo. Feb. 11, 2025).
- Baton Rouge Ventures, LLC v. Cedar Grove Capital, LLC, No. 3:20-cv-00628 (M.D. La. Jan. 21, 2025).
- Townsend, No. 3:25-cv-00445 (N.D. Ind. Oct. 22, 2025).
- Rivlin, No. 3:24-cv-05789 (D.N.J. Nov. 24, 2025).unpublished
- Glengarry, L.L.C., & Angus M. Peyton, Co-Tr. of the Angus Eugene Peyton Irrevocable Trust II v. Andrew Normand Peyton Morin & William Briscoe Morin & Lisa P. Morin, Co-Tr. of the Angus Eugene Peyton Irrevocable Trust II, & Donald R. Morin, Co-Tr. of the Angus Eugene Peyton Irrevocable Trust II, No. 5:25-cv-00157 (S.D. W. Va. Feb. 24, 2026).
- Robert Ryan Johnson, as Ex'r & Rep. of the Est. of Terrence Blair Hunter, et al. v. Stand. Registrar & Transfer, a Utah Corp., et al., No. 2:22-cv-00591 (D. Utah July 31, 2026).
- Sung-Chul Jung v. Fairfax Taxi, Inc., No. 25-1702 (4th Cir. Aug. 19, 2026).published
- Cabello, No. 1:26-cv-01900 (W.D. Tex. Aug. 4, 2026).
136 S. Ct. at 1014 Determining citizenship of artificial entities35 citing cases�While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.
- Se. Solutions SES Inc. v. Icon Realty NY Corp., No. 1:24-cv-08995 (S.D.N.Y. May 6, 2025).(While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
- Goney v. SuttonPark Capital LLC, No. 1:20-cv-05387 (S.D.N.Y. Dec. 21, 2023).(While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
- NY United A-1 Constr., Inc. v. J.P. Mgmt., LLC, No. 1:22-cv-04583 (S.D.N.Y. Apr. 12, 2023).(While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
- Rose v. Mesabi Metallics Co. LLC, No. 1:22-cv-05832 (S.D.N.Y. Aug. 10, 2022).(While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
- JMB Shipping ATB 284, LLC v. Unico Commodities LLC, Inc., No. 1:21-cv-08907 (S.D.N.Y. Feb. 25, 2022).(While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
- Patrick Capital Markets, LLC v. Ascend Real Est. Partners, L.P., No. 1:21-cv-06004 (S.D.N.Y. Feb. 1, 2022).(While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
- Westchester Fire Ins. Co. v. Solar OpCo, LLC, No. 1:21-cv-06232 (S.D.N.Y. Oct. 26, 2021).(While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
- Honig v. Hansen, No. 1:20-cv-05872 (S.D.N.Y. Aug. 9, 2021). (While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
- Medequa LLC v. O'Neill & Partners LLC, No. 1:21-cv-06135 (S.D.N.Y. Aug. 3, 2021).(While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
- Lightstone Acquisitions III, LLC v. Phillips, No. 1:20-cv-06051 (S.D.N.Y. Nov. 4, 2020).(While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
Show 25 more citing cases
- Gauge By Design, Ltd. v. Coldwater Direct LLC, No. 1:20-cv-06230 (S.D.N.Y. Aug. 12, 2020).(While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
- MMA Fighter Mgmt., Inc. v. Ballengee Grp., LLC, No. 1:19-cv-11276 (S.D.N.Y. Dec. 16, 2019).(While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
- Wang Ex Rel. Wong v. New Mighty U.S. Trust, 843 F.3d 487 (D.C. Cir. 2016).published
- Rosas v. NFI Indus., No. 2:21-cv-00046 (E.D. Cal. Feb. 22, 2021).
- Equity Trust Co. Custodian v. Windwrap, LLC, No. 1:19-cv-03048 (N.D. Ill. Mar. 26, 2020).
- Carrington Square, LLC v. Steeley, No. 2:19-cv-02386 (D. Kan. July 23, 2019).
- L6, Inc. v. Woodrow, LLC, No. 2:19-cv-02403 (D. Kan. July 18, 2019).
- Poulos v. Brickley Holdings, Inc., No. 2:19-cv-02629 (D. Kan. Oct. 15, 2019).
- Wingate v. Barkman Honey, LLC, No. 5:19-cv-04074 (D. Kan. Oct. 29, 2019).
- Rabin v. Bill Gosling Outsourcing Corp., No. 2:19-cv-02771 (D. Kan. Feb. 3, 2020).
- Auto-Owners Mut. Ins. Co. v. Bricks & Stones, LLC, No. 2:20-cv-02365 (D. Kan. Sept. 9, 2020).
- Jackson v. Wal-Mart Stores East, LP, No. 2:20-cv-02469 (D. Kan. Sept. 28, 2020).
- Kansas St Gregorys LLC v. Otis Elevator Co., No. 5:20-cv-04054 (D. Kan. Oct. 28, 2020).
- Stevens v. Yusuf, No. 2:21-cv-02155 (D. Kan. Sept. 10, 2021).
- Yusuf v. Stevens, No. 2:21-cv-02313 (D. Kan. Sept. 23, 2021).
- Les Indus. Wipeco, Inc. v. Bluestem Mgmt. Advisors, LLC, No. 2:21-cv-02289 (D. Kan. Sept. 28, 2021).
- Adams v. Integral Senior Living Mgmt., LLC, No. 2:21-cv-02378 (D. Kan. Nov. 12, 2021).
- Rathbun v. Off. Depot LLC, No. 6:21-cv-01279 (D. Kan. Dec. 2, 2021).
- Vazquez v. Gomez, No. 6:21-cv-01263 (D. Kan. Dec. 1, 2021).
- Green v. Buttonwood Tree, Gr LLC, No. 6:21-cv-01273 (D. Kan. Dec. 14, 2021).
- Vazquez v. Gomez, No. 6:21-cv-01263 (D. Kan. Dec. 16, 2021).
- Keller v. Diversicare of Council Grove, LLC, No. 2:23-cv-02556 (D. Kan. Mar. 7, 2024).
- St Paul Fire & Marine Ins. Co v. Covington Co Inc, No. 5:20-cv-01458 (W.D. La. June 7, 2021).
- 5J's Holding, LLC v. Old South Trading Co., LLC, No. 4:22-cv-00858 (E.D. Mo. Dec. 8, 2022).
- Twenty X, LLC v. Bombardier, Inc., No. 1:25-cv-01512 (S.D.N.Y. June 18, 2025).
577 U.S. at 379 Determining citizenship of various types of entities26 citing casesWhile humans and corporations can assert their own citizenship, other entities take the citizenship of their members.
- Rini, No. 9:25-cv-13348 (D.S.C. June 9, 2026).(While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
- Palmetto Bluff Investments, LLC v. Westchester Surplus Lines Ins. Co., a Georgia Corp., & ACE Fire Underwriters Ins. Co., a Pennsylvania Corp., No. 9:23-cv-05263 (D.S.C. Mar. 10, 2026).(While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
- Huawei Tech. Co., Ltd. v. Panoptis Pat. Mgmt., LLC, No. 1:24-cv-04708 (S.D.N.Y. July 31, 2025).(While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
- Se. Solutions SES Inc. v. Icon Realty NY Corp., No. 1:24-cv-08995 (S.D.N.Y. May 6, 2025).P’ship, 213 F.3d 48 , 51 (2d Cir. 2000) (citing Carden v. Arkoma Assocs., 494 U.S. 185 (1990)); see also Americold Realty Trust v. Conagra Foods, Inc., 136 S. Ct. 1012, 1014 (2016) (“While humans and corporations can assert their own citiz…
- Goney v. SuttonPark Capital LLC, No. 1:20-cv-05387 (S.D.N.Y. Dec. 21, 2023).P’ship, 213 F.3d 48 , 51 (2d Cir. 2000) (citing Carden v. Arkoma Assocs., 494 U.S. 185 (1990)); see also Americold Realty Trust v. Conagra Foods, Inc., 136 S. Ct. 1012, 1014 (2016) (“While humans and corporations can assert their own citiz…
- NY United A-1 Constr., Inc. v. J.P. Mgmt., LLC, No. 1:22-cv-04583 (S.D.N.Y. Apr. 12, 2023).P’ship, 213 F.3d 48 , 51 (2d Cir. 2000) (citing Carden v. Arkoma Assocs., 494 U.S. 185 (1990)); see also Americold Realty Trust v. Conagra Foods, Inc., 136 S. Ct. 1012, 1014 (2016) (“While humans and corporations can assert their own citiz…
- Rose v. Mesabi Metallics Co. LLC, No. 1:22-cv-05832 (S.D.N.Y. Aug. 10, 2022).P’ship, 213 F.3d 48 , 51 (2d Cir. 2000) (citing Carden v. Arkoma Assocs., 494 U.S. 185 (1990)); see also Americold Realty Trust v. Conagra Foods, Inc., 136 S. Ct. 1012, 1014 (2016) (“While humans and corporations can assert their own citiz…
- JMB Shipping ATB 284, LLC v. Unico Commodities LLC, Inc., No. 1:21-cv-08907 (S.D.N.Y. Feb. 25, 2022).P’ship, 213 F.3d 48 , 51 (2d Cir. 2000) (citing Carden v. Arkoma Assocs., 494 U.S. 185 (1990)); see also Americold Realty Trust v. Conagra Foods, Inc., 136 S. Ct. 1012, 1014 (2016) (“While humans and corporations can assert their own citiz…
- Patrick Capital Markets, LLC v. Ascend Real Est. Partners, L.P., No. 1:21-cv-06004 (S.D.N.Y. Feb. 1, 2022).P’ship, 213 F.3d 48 , 51 (2d Cir. 2000) (citing Carden v. Arkoma Assocs., 494 U.S. 185 (1990)); see also Americold Realty Trust v. Conagra Foods, Inc., 136 S. Ct. 1012, 1014 (2016) (“While humans and corporations can assert their own citiz…
- Westchester Fire Ins. Co. v. Solar OpCo, LLC, No. 1:21-cv-06232 (S.D.N.Y. Oct. 26, 2021).P’ship, 213 F.3d 48 , 51 (2d Cir. 2000) (citing Carden v. Arkoma Assocs., 494 U.S. 185 (1990)); see also Americold Realty Trust v. Conagra Foods, Inc., 136 S. Ct. 1012, 1014 (2016) (“While humans and corporations can assert their own citiz…
Show 16 more citing cases
- Honig v. Hansen, No. 1:20-cv-05872 (S.D.N.Y. Aug. 9, 2021). P’ship, 213 F.3d 48 , 51052 (2d Cir. 2000) (citing Carden v. Arkoma Assocs., 494 U.S. 185 , 195- 96 (1990)); see also Americold Realty Tr. v. Conagra Foods, Inc., 136 S. Ct. 1012, 1014 (2016) (“While humans and corporations can assert thei…
- Medequa LLC v. O'Neill & Partners LLC, No. 1:21-cv-06135 (S.D.N.Y. Aug. 3, 2021).P’ship, 213 F.3d 48 , 51 (2d Cir. 2000) (citing Carden v. Arkoma Assocs., 494 U.S. 185 (1990)); see also Americold Realty Trust v. Conagra Foods, Inc., 136 S. Ct. 1012, 1014 (2016) (“While humans and corporations can assert their own citiz…
- Lightstone Acquisitions III, LLC v. Phillips, No. 1:20-cv-06051 (S.D.N.Y. Nov. 4, 2020).P’ship, 213 F.3d 48 , 51052 (2d Cir. 2000) (citing Carden v. Arkoma Assocs., 494 U.S. 185, 195-96 (1990)); see also Americold Realty Tr. v. Conagra Foods, Inc., 136 S. Ct. 1012, 1014 (2016) (“While humans and corporations can assert their…
- Gauge By Design, Ltd. v. Coldwater Direct LLC, No. 1:20-cv-06230 (S.D.N.Y. Aug. 12, 2020).P’ship, 213 F.3d 48 , 51052 (2d Cir. 2000) (citing Carden v. Arkoma Assocs., 494 U.S. 185 , 195- 96 (1990)); see also Americold Realty Tr. v. Conagra Foods, Inc., 136 S. Ct. 1012, 1014 (2016) (“While humans and corporations can assert thei…
- MMA Fighter Mgmt., Inc. v. Ballengee Grp., LLC, No. 1:19-cv-11276 (S.D.N.Y. Dec. 16, 2019).P’ship, 213 F.3d 48 , 51 (2d Cir. 2000) (citing Carden v. Arkoma Assocs., 494 U.S. 185 (1990)); see also Americold Realty Tr. v. Conagra Foods, Inc., 136 S. Ct. 1012, 1014 (2016) (“While humans and corporations can assert their own citizen…
- Taylor v. BMW of North Am., LLC, No. 2:20-cv-01994, 2021 WL 1186777 (D.N.J. Mar. 29, 2021).Americold Realty Tr. v. Conagra Foods, Inc., 136 S. Ct. 1012 , 1014-15 (2016) (“While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.”).
- Equity Trust Co. Custodian v. Windwrap, LLC, No. 1:19-cv-03048 (N.D. Ill. Mar. 26, 2020).
- Citibank, N.A. v. Najda, No. 1:14-cv-13593 (D. Mass. Sept. 7, 2023).
- Wyndham Hotel Grp. Canada, Ulc v. Ostrander, No. 2:21-cv-16333, 2022 WL 16552817 (D.N.J. Oct. 31, 2022).
- Unified Sys. Div. BMWED-IBT v. Biden, No. 2:21-cv-00700 (D. Utah June 17, 2022).
- Fedele v. West Shore Home, LLC, No. 1:24-cv-00506 (M.D.N.C. Dec. 20, 2024).
- Osk XIV, LLC v. Tdc Blue IV, LLC, No. 1:23-cv-00949 (M.D.N.C. Jan. 23, 2025).
- Nguyen v. Choice Home Warranty, No. 1:24-cv-00844 (M.D.N.C. Jan. 30, 2025).
- Scps, LLC v. Kind Law, 770 F. Supp. 3d 11 (D.D.C. 2025).published
- ADA Carbon Solutions (Red River) v. Atlas Carbon, 146 F.4th 1296 (10th Cir. 2025).published
- Joan Demarest v. HSBC Bank USA, 920 F.3d 1223 (9th Cir. 2019).published
577 U.S. at 380 Determining citizenship of non-corporate artificial entities7 citing casesaffirming the Tenth Circuit’s holding that “the citizenship of any ‘non-corporate artificial entity’ is determined by considering all of the entity’s ‘members’
- McClurg v. Oliver, No. 2:21-cv-00381 (M.D. Fla. Aug. 5, 2021).
- SFR Servs. LLC v. Heritage Prop. & Cas. Ins. Co., No. 2:22-cv-00573 (M.D. Fla. Nov. 10, 2022).
- 600 Tpk. RHD Trust v. North East Freightways, Inc., No. 1:20-cv-40144 (D. Mass. Jan. 13, 2022).
- Hilcorp San Juan, L.P. v. Petro Mex, LLC, No. 1:24-cv-00067 (D.N.M. Mar. 20, 2024).
- Vargo v. EVO Transp. & Energy Servs., Inc., No. 1:24-cv-00301 (D.N.M. Apr. 1, 2024).
- Lopez v. United Van Lines, LLC, No. 1:23-cv-01127 (D.N.M. Apr. 1, 2024).
- Katsel v. Alibaba Grp. Holding Ltd., No. 1:25-cv-00699 (D. Colo. Oct. 7, 2025).
136 S. Ct. at 1016 “traditionally, a trust was not considered a distinct legal entity, but a 'fiduciary relationship' between multiple people.”6 citing cases
- Michael Bynane v. The Bank of New York Mellon, et, No. 16-20598 (5th Cir. Aug. 4, 2017).published (And when a trustee files a lawsuit or is sued in her own name, her citizenship is all that matters for diversity purposes.)
- Zoroastrian Ctr. & Darb-E-Mehr v. Rustam Guiv Found., 822 F.3d 739 (4th Cir. 2016).published([Cjonfusion regarding the citizenship of a trust is understandable and widely shared.)
- Stream Fam. Ltd. P'ship v. Targa Midstream Servs. LLC, No. 2:25-cv-01856 (W.D. La. Sept. 15, 2026). “for a traditional trust, therefore, there is no need to determine its membership, as would be true if the trust, as an entity, were sued.”
- U.S. Bank Nat'l Ass'n v. Desrosiers, No. 2:17-cv-07338 (E.D.N.Y. Dec. 1, 2021). “shareholders of a real estate trust appear to be in the same position as the shareholders of a joint-stock company or the partners of a limited partnership . . . for purposes of diversity jurisdiction, members of a real…”
- Hicks v. Heart of Hospice, LLC, No. 4:19-cv-00106 (N.D. Miss. Nov. 22, 2019).“so long as such an entity is unincorporated, we apply our oft-repeated rule that it possesses the citizenship of all its members. but neither this rule nor navarro limits an entity's membership to its trustees just beca…”
- Arneault v. Diamondhead Casino Corp., 277 F. Supp. 3d 671 (D. Del. 2017).published “when a trustee files a lawsuit or is sued in her own name, her citizenship is all that matters for diversity purposes. for. a traditional trust, therefore, there is no need to determine its membership, as would be true…”
577 U.S. at 384 Applying corporate citizen doctrine to unincorporated entities3 citing casesdeclining "to apply the same rule to an unincorporated entity that applies to a corporation— namely, to consider it a citizen only of its State of establishment and its principal place of business.
- Euclid Turnaround Opportunity Fund LP v. Amerant Equip. Fin., No. 1:25-cv-20647 (S.D. Fla. June 10, 2025). (When we last examined the ‘doctrinal wall’ between corporate and unincorporated entities in [Carden], we saw no reason to tear it down.)
- Liveious v. Caesars Ent., Inc, No. 4:24-cv-00145 (S.D. Ind. July 18, 2025).
- Levy, No. 1:24-cv-01667 (E.D. Wis. Mar. 24, 2026).
For a traditional trust, therefore, there is no need to determine its membership, as would be true if the trust, as an entity, were sued.
- Stream Fam. Ltd. P'ship v. Targa Midstream Servs. LLC, No. 2:25-cv-01856 (W.D. La. Sept. 15, 2026). (For a traditional trust, therefore, there is no need to determine its membership, as would be true if the trust, as an entity, were sued.)
- Halibut Trust v. Floerchinger, No. 4:20-cv-00005 (D. Alaska May 13, 2020). (For a traditional trust . . . there is no need to determine its membership, as would be true if the trust, as an entity, were sued. . . . We . . . decline to apply the same rule to an unincorporated entity sued in its…)
- Arneault v. Diamondhead Casino Corp., 277 F. Supp. 3d 671 (D. Del. 2017).published (When a trustee files a lawsuit or is sued in her own name, her citizenship is all that matters for diversity purposes. For. a traditional trust, therefore, there is no need to determine its membership, as would be true…)
136 S. Ct. at 1015 “possesses the citizenship of all its members.”2 citing cases
- Karpel v. Gebrueder Knauf Verwaltungsgesellschaft, KG, No. 1:21-cv-24168 (S.D. Fla. June 6, 2023). ([W]e have identified . . . the members of a partnership as its partners[.])
- Hicks v. Heart of Hospice, LLC, No. 4:19-cv-00106 (N.D. Miss. Nov. 22, 2019).(So long as such an entity is unincorporated, we apply our oft-repeated rule that it possesses the citizenship of all its members. But neither this rule nor Navarro limits an entity’s membership to its trustees just bec…)
136 S. Ct. at 1012 “while humans and corporations can assert their own citizenship, other entities take the citizenship of their members.”1 citing case
- Taylor v. BMW of North Am., LLC, No. 2:20-cv-01994, 2021 WL 1186777 (D.N.J. Mar. 29, 2021).(While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.)
136 S. Ct. at 1017 “for a traditional trust . . . there is no need to determine its membership, as would be true if the trust, as an entity, were sued. . . . we . . . decline to apply the same rule to an unincorporated entity sued in its organizational name that applies to a human trustee sued in her personal name.”1 citing case
- Halibut Trust v. Floerchinger, No. 4:20-cv-00005 (D. Alaska May 13, 2020). “for a traditional trust . . . there is no need to determine its membership, as would be true if the trust, as an entity, were sued. . . . we . . . decline to apply the same rule to an unincorporated entity sued in its o…”
Other citing cases
- Enriquez, No. 2:26-cv-00109 (D.N.M. Jan. 27, 2026).
- Klein v. Menard, Inc., No. 0:24-cv-02362 (D. Minn. Nov. 25, 2024).
- Alliant Tax Credit 31, Inc. v. M. Vincent Murphy, III, 924 F.3d 1134 (11th Cir. 2019).published
- Jakks Pac., Inc. v. Accasvek, LLC, 270 F. Supp. 3d 191 (D.D.C. 2017).published
v.
CONAGRA FOODS, INC., Et Al.
Federal law permits federal courts to resolve certain nonfederal controversies between "citizens" of different States. This rule is easy enough to apply to humans, but can become metaphysical when applied to legal entities. This case asks how to determine the citizenship of a "real estate investment trust," an inanimate creature of Maryland law. We answer: While humans and corporations can assert their own citizenship, other entities take the citizenship of their members.
I
This action began as a typical state-law controversy, one involving a contract dispute and an underground food-storage warehouse fire. A group of corporations whose food perished in that 1991 fire continues to seek compensation from the warehouse's owner, now known as Americold Realty Trust. After the corporations filed their latest suit in Kansas court, Americold removed the suit to the Federal District Court for the District of Kansas. The District Court accepted jurisdiction and resolved the dispute in favor of Americold.
On appeal, however, the Tenth Circuit asked for supplemental briefing on whether the District Court's exercise of jurisdiction was appropriate. The parties responded that the District Court possessed jurisdiction because the suit involved "citizens of different States." 28 U.S.C. §§ 1332 (a)(1), 1441(b).
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: Delaware, Nebraska, and Illinois. See ConAgra Foods, Inc. v. Americold Logistics, LLC, 776 F.3d 1175 , 1182 (2015) ; § 1332(c)(1) (specifying the citizenship of corporations for jurisdictional purposes). The court applied a different test to determine Americold's citizenship because Americold is a "real estate investment trust," not a corporation. Distilling this Court's[*1015] precedent, the Tenth Circuit reasoned 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. Id., at 1180-1181 (citing Carden v. Arkoma Associates, 494 U.S. 185 , 110 S.Ct. 1015 , 108 L.Ed.2d 157 (1990) ). As there was no record of the citizenship of Americold's shareholders, the court concluded that the parties failed to demonstrate that the plaintiffs were "citizens of different States" than the defendants. See Strawbridge v. Curtiss, 3 Cranch 267 , 2 L.Ed. 435 (1806).
We granted certiorari to resolve confusion among the Courts of Appeals regarding the citizenship of unincorporated entities. 576 U.S. ----, 136 S.Ct. 27 , 192 L.Ed.2d 997 (2015). We now affirm.
II
Exercising its powers under Article III, the First Congress granted federal courts jurisdiction over controversies between a "citizen" of one State and "a citizen of another State." 1 Stat. 78 . For a long time, however, Congress failed to explain how to determine the citizenship of a nonbreathing entity like a business association. In the early 19th century, this Court took that silence literally, ruling that only a human could be a citizen for jurisdictional purposes. Bank of United States v. Deveaux, 5 Cranch 61 , 86-91, 3 L.Ed. 38 (1809). If a "mere legal entity" like a corporation were sued, the relevant citizens were its "members," or the "real persons who come into court" in the entity's name. Id., at 86, 91 .
This Court later carved a limited exception for corporations, holding that a corporation itself could be considered a citizen of its State of incorporation. See Louisville, C. & C.R. Co. v. Letson, 2 How. 497 , 558, 11 L.Ed. 353 (1844). Congress etched this exception into the U.S. Code, adding that a corporation should also be considered a citizen of the State where it has its principal place of business. 28 U.S.C. § 1332 (c) (1958 ed.). But Congress never expanded this grant of citizenship to include artificial entities other than corporations, such as joint-stock companies or limited partnerships. For these unincorporated entities, we too have "adhere[d] to our oft-repeated rule that diversity jurisdiction in a suit by or against the entity depends on the citizenship of 'all [its] members.' " Carden, 494 U.S., at 195-196 , 110 S.Ct. 1015 (quoting Chapman v. Barney, 129 U.S. 677 , 682, 9 S.Ct. 426 , 32 L.Ed. 800 (1889) ).
Despite our oft-repetition of the rule linking unincorporated entities with their "members," we have never expressly defined the term. But we have equated an association's members with its owners or " 'the several persons composing such association.' " Carden, 494 U.S., at 196 , 110 S.Ct. 1015 (quoting Great Southern Fire Proof Hotel Co. v. Jones, 177 U.S. 449 , 456, 20 S.Ct. 690 , 44 L.Ed. 842 (1900) ). Applying this principle with reference to specific States' laws, we have identified the members of a joint-stock company as its shareholders, the members of a partnership as its partners, the members of a union as the workers affiliated with it, and so on. See Carden, 494 U.S., at 189-190 , 110 S.Ct. 1015 (citing Chapman, 129 U.S., at 682 , 9 S.Ct. 426 ; Great Southern, 177 U.S., at 457 , 20 S.Ct. 690 ; and Steelworkers v. R.H. Bouligny, Inc., 382 U.S. 145 , 146, 86 S.Ct. 272 , 15 L.Ed.2d 217 (1965) ).
This case asks us to determine the citizenship of Americold Realty Trust, a "real estate investment trust" organized under Maryland law. App. 93. As Americold is not a corporation, it possesses its members' citizenship. Nothing in the record designates who Americold's members[*1016] are. But Maryland law provides an answer.
In Maryland, a real estate investment trust is an "unincorporated business trust or association" in which property is held and managed "for the benefit and profit of any person who may become a shareholder." Md. Corp. & Assns. Code Ann. §§ 8-101(c), 8-102 (2014). As with joint-stock companies or partnerships, shareholders have "ownership interests" and votes in the trust by virtue of their "shares of beneficial interest." §§ 8-704(b)(5), 8-101(d). These shareholders appear to be in the same position as the shareholders of a joint-stock company or the partners of a limited partnership-both of whom we viewed as members of their relevant entities. See Carden, 494 U.S., at 192-196 , 110 S.Ct. 1015 ; see also § 8-705(a) (linking the term "beneficial interests" with "membership interests" and "partnership interests"). We therefore conclude that for purposes of diversity jurisdiction, Americold's members include its shareholders.
III
Americold disputes this conclusion. It cites a case called Navarro Savings Assn. v. Lee, 446 U.S. 458 , 100 S.Ct. 1779 , 64 L.Ed.2d 425 (1980), to argue that anything called a "trust" possesses the citizenship of its trustees alone, not its shareholder beneficiaries as well. As we have reminded litigants before, however, " Navarro had nothing to do with the citizenship of [a] 'trust.' " Carden, 494 U.S., at 192-193 , 110 S.Ct. 1015 . Rather, Navarro reaffirmed a separate rule that when a trustee files a lawsuit in her name, her jurisdictional citizenship is the State to which she belongs-as is true of any natural person. 446 U.S., at 465 , 100 S.Ct. 1779 . This rule coexists with our discussion above that when an artificial entity is sued in its name, it takes the citizenship of each of its members.
That said, Americold's confusion regarding the citizenship of a trust is understandable and widely shared. See Emerald Investors Trust v. Gaunt Parsippany Partners, 492 F.3d 192 , 201-206 (C.A.3 2007) (discussing various approaches among the Circuits). The confusion can be explained, perhaps, by tradition. Traditionally, a trust was not considered a distinct legal entity, but a "fiduciary relationship" between multiple people. Klein v. Bryer, 227 Md. 473 , 476-477, 177 A.2d 412 , 413 (1962) ; Restatement (Second) of Trusts § 2 (1957). Such a relationship was not a thing that could be haled into court; legal proceedings involving a trust were brought by or against the trustees in their own name. Glenn v. Allison, 58 Md. 527 , 529 (1882) ; Deveaux, 5 Cranch, at 91. And when a trustee files a lawsuit or is sued in her own name, her citizenship is all that matters for diversity purposes. Navarro, 446 U.S., at 462-466 , 100 S.Ct. 1779 . For a traditional trust, therefore, there is no need to determine its membership, as would be true if the trust, as an entity, were sued.
Many States, however, have applied the "trust" label to a variety of unincorporated entities that have little in common with this traditional template. Maryland, for example, treats a real estate investment trust as a "separate legal entity" that itself can sue or be sued. Md. Corp. & Assns. Code Ann. §§ 8-102(2), 8-301(2). So long as such an entity is unincorporated, we apply our "oft-repeated rule" that it possesses the citizenship of all its members. Carden, 494 U.S., at 195 , 110 S.Ct. 1015 . But neither this rule nor Navarro limits an entity's membership to its trustees just because the entity happens to call itself a trust.
[*1017] We therefore decline to apply the same rule to an unincorporated entity sued in its organizational name that applies to a human trustee sued in her personal name. We also decline an amicus ' invitation to apply the same rule to an unincorporated entity that applies to a corporation-namely, to consider it a citizen only of its State of establishment and its principal place of business. See Brief for National Association of Real Estate Investment Trusts 11-21. When we last examined the "doctrinal wall" between corporate and unincorporated entities in 1990, we saw no reason to tear it down. Carden, 494 U.S., at 190 , 110 S.Ct. 1015 . Then as now we reaffirm that it is up to Congress if it wishes to incorporate other entities into 28 U.S.C. § 1332 (c)'s special jurisdictional rule.
* * *
For these reasons, the judgment of the Court of Appeals is
Affirmed.