Whose citizenship counts for trusts
Americold Realty Trust v. ConAgra Foods
In brief
The Supreme Court left the appeals court’s ruling in place: Americold’s shareholders count in determining its citizenship for diversity jurisdiction.
- Where it stands
- Decided
Decided 8-0 · March 7, 2016 · Opinion by Justice Sotomayor
- What it’s about
- Food distributors including ConAgra sued Americold over a contract dispute tied to a warehouse fire; Americold sought to move the case to federal court based on its trustees’ citizenship.
- Who it affects
- Americold’s shareholders, not just its trustees, count when determining its citizenship for diversity jurisdiction.
Summary: written with AI from the case record.
What it's about
The Supreme Court agreed with the appeals court (affirmed) that an unincorporated trust’s citizenship for diversity jurisdiction depends on all its members, including shareholder-beneficiaries.
Food distributors, including ConAgra, sued Americold over a contract dispute tied to a warehouse fire. Americold sought to move the case to federal court based on its trustees’ citizenship.
The dispute turned on whether a trust’s citizenship depends only on its trustees or also on its shareholder-beneficiaries.
Question presented
Is the citizenship of a trust for the purposes of diversity jurisdiction based on the diversity of the trust’s beneficiaries (who are its shareholders) as well as the trustees?
What the Court decided
Holding
For purposes of diversity jurisdiction, Americold’s citizenship is based on the citizenship of its members, which include its shareholders. 776 F. 3d 1175, affirmed.
- Result
- Affirmed
The Court's reasoning
The Court said Americold’s citizenship depends on its members. Because its members include shareholders, their citizenship counts too.
The vote
What's next
The appeals court’s ruling remains in place. For this diversity-jurisdiction question, Americold’s shareholders count among its members.
Documents
Opinions
Docket activity
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AI analysis generated: Case Briefing
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Opinion added: Americold
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.