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Schneiderman v. American Chemical Society - Diversity Jurisdiction Ruling

The Second Circuit affirmed the dismissal of plaintiff Arnold Schneiderman's disability discrimination lawsuit against the American Chemical Society for lack of subject matter jurisdiction. The court held that 28 U.S.C. § 1332(c)(1)'s principal-place-of-business provision does not independently establish corporate citizenship for diversity purposes—it applies only in conjunction with the state-of-incorporation provision. Because ACS is a federally chartered corporation not incorporated by any state, it is not a citizen of any state for diversity jurisdiction purposes. Judge Menashi dissented.