Hertz Corp. v. Friend
Issues
What factors should courts look to when determining the “citizenship” of a multistate corporation to determine whether or not to exercise diversity jurisdiction?
Though federal courts are generally only able to hear claims arising under federal law, Congress gives them the power to exercise so-called “diversity jurisdiction” over any state law civil claim between citizens of different states. When a multistate corporation seeks relief in federal court on the basis of a diversity action, courts wrestle with exactly what factors they should look to in determining the corporation’s citizenship. Here, a group of California citizens sued Hertz Corporation in California state court alleging violations of California’s state labor laws. Hertz sought to remove the case to federal court. The Ninth Circuit concluded Hertz was a California citizen and denied removal jurisdiction. This case presents the Supreme Court with the opportunity to lay out a specific test for determining corporate citizenship for the purposes of diversity jurisdiction.
Questions as Framed for the Court by the Parties
Whether, for purposes of determining principal place of business for diversity jurisdiction citizenship under 28 U.S.C. § 1332, a court can disregard the location of a nationwide corporation's headquarters - i.e., its nerve center.
Congress gives federal district courts the power to exercise “diversity jurisdiction” over any civil claim for at least $75,000 arising between citizens of different states. See 28 U.S.C.