“Americold Realty Trust v. ConAgra Foods, Inc.”的意思、由来-开放百科全书

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]

Background

Federal diversity jurisdiction

Initial lawsuit and appeal to the United States Court of Appeals for the Tenth Circuit

The case began as a contract dispute that arose when food owned by ConAgra Foods and other corporations was destroyed in a 1991 warehouse fire.^[13] The corporations sued the warehouse's owner, which is now known as Americold Realty Trust, in a state court in Kansas.^[13] The case was later removed to the United States District Court for the District of Kansas, and the district court ultimately ruled in favor of Americold.^[13] On appeal, the United States Court of Appeals for the Tenth Circuit held that district court did not have jurisdiction to hear the case.^[3] The parties argued that the district court could assert diversity jurisdiction in this case because the parties were citizens of different states, but the Tenth Circuit disagreed.^[3] The Tenth Circuit held that the citizenship of the corporate plaintiffs should be determined according to "where they were chartered and had their principal places of business", but that Americold (a real estate investment trust) should be considered a citizen of every state in which its shareholders were citizens.^[3]{{efn-ua|The Tenth Circuit held that the citizenship of a "non-corporate artificial entity" should be determined according to the citizenship of its members or shareholders.^[14]|group=fn}} Because there was "no record of the citizenship of Americold’s shareholders", the Tenth Circuit ruled that the parties had failed to prove they were citizens of different states.^[3] Americold appealed the Tenth Circuit's ruling, and the Supreme Court of the United States granted certiorari to resolve a circuit split "regarding the citizenship of unincorporated entities."^[3]

Opinion of the Court

Writing for a unanimous Court, Justice Sonia Sotomayor held that real estate investment trusts, as defined by Maryland law, should be treated like other unincorporated entities when determining diversity jurisdiction.^[16] Consequently, Justice Sotomayor ruled that "diversity jurisdiction in a suit by or against the entity depends on the citizenship of all its members."^[17] Because Maryland real estate investment trusts are unincorporated organizations "in which property is held and managed for the benefit and profit of any person who may become a shareholder”, Justice Sotomayor explained that shareholders of Maryland real estate investment trusts "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."^[18] Therefore, for the purposes of determining whether diversity of citizenship exists, Justice Sotomayor held that "Americold’s members include its shareholders."^[19]

Commentary and analysis

In his analysis of the case for SCOTUSblog, Ronald Mann wrote that the case "seems most unlikely to have any broad or long-term impact" and that the "most likely fate" of the case "is an occasional appearance in the footnotes of casebooks and treatises on federal courts."^[5] Mann also observed that "Chief Justice John Roberts has not yet assigned any major opinions to Sotomayor, and this case leaves that pattern intact."^[5] Amy Howe also wrote 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]

See also

Notes

References

1. ^Americold Realty Trust v. ConAgra Foods, Inc., No. 14–1382, 577 U.S. ___, slip op. at 1, 4 (2016) (internal quotations omitted).
2. ^Americold, slip op. at 1; Amy Howe, Trusts and citizenship: It is an easy question for the Court, {{smallcaps|Howe on the Court}} (Mar. 7, 2016) (noting that "millions of tons" of food were destroyed).
3. ^¹²³⁴⁵⁶⁷Americold, slip op. at 2.
4. ^Americold, slip op. at 1–4, 6 (internal quotations omitted).
5. ^¹²Ronald Mann, Opinion analysis: Justices choose bright-line rule limiting diversity jurisdiction over business trusts, {{smallcaps|SCOTUSblog}} (Mar. 7, 2016).
6. ^¹Amy Howe, Trusts and citizenship: It is an easy question for the Court, {{smallcaps|Howe on the Court}} (Mar. 7, 2016).
7. ^{{USC|28|1332}}.
8. ^See generally George W. Ball, Revision of Federal Diversity Jurisdiction, 28 {{smallcaps|Ill. L. Rev.}} 356 (1933).
9. ^See {{ussc|name=Louisville, C. & C. R. Co. v. Letson|link=|volume=43|page=497|pin=558|year=1844|reporter=How.|reporter-volume=2}}.
10. ^Americold, slip op. at 3 (citing 28 U.S.C. § 1332(c) (1958 ed.)).
11. ^Carden v. Arkoma Associates, {{ussc|volume=494|page=185|year=1990}}.
12. ^See Carden, 494 U.S. at 189–90.
13. ^¹²Americold, slip op. at 1.
14. ^ConAgra Foods, Inc. v. Americold Logistics, LLC, [https://www.leagle.com/decision/infco20150127107 776 F.3d 1175], 1180–81 (2015) (citing Carden v. Arkoma Associates, {{ussc|volume=494|page=185|year=1990}}).
15. ^Americold, slip op. at 6 (citing Carden, 494 U.S. at 190) (internal citations omitted).
16. ^Americold, slip op. at 3.
17. ^Americold, slip op. at 3 (citing Carden v. Arkoma Associates, {{ussc|volume=494|page=185|year=1990}}) (internal quotations and modifications omitted).
18. ^Americold, slip op. at 3 (citing Md. Corp. & Assns. Code Ann. §§ 8–704(b)(5), 8–101(d) (2014)) (internal quotations omitted).
19. ^Americold, slip op. at 4.