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Schneiderman v. American Chemical Society — Diversity Jurisdiction Affirmed

The Second Circuit affirmed dismissal of a disability discrimination suit against the American Chemical Society, holding that 28 U.S.C. § 1332(c)(1) requires state incorporation to establish corporate citizenship for diversity jurisdiction purposes. Because ACS is a federally chartered corporation not incorporated by any State, it lacks a State of citizenship under the statute, and diversity jurisdiction was not established. Judge Menashi dissented. The ruling clarifies that federally chartered corporations cannot be sued in federal court based solely on their principal place of business under § 1332(c)(1).

Schneiderman v. American Chemical Society - Diversity Jurisdiction Ruling

The Second Circuit affirmed dismissal of plaintiff Arnold Schneiderman's disability discrimination suit against the American Chemical Society, holding that federal diversity jurisdiction under 28 U.S.C. § 1332(c)(1) was not established. The court interpreted the statute's principal-place-of-business provision as applying only in conjunction with the state-of-incorporation provision, such that federally chartered corporations without state incorporation cannot invoke diversity jurisdiction based solely on having a principal place of business in a state. This ruling clarifies that entities chartered by federal statute rather than state law fall outside § 1332(c)(1)'s scope.