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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.

Schneiderman v. American Chemical Society - Diversity Jurisdiction and Disability Discrimination Appeal

The Second Circuit affirmed dismissal of plaintiff Arnold Schneiderman's disability discrimination suit against the American Chemical Society (ACS), holding that federal diversity jurisdiction under 28 U.S.C. § 1332(c)(1) does not extend to federally chartered corporations. The court held that ACS, as a federally chartered corporation with principal place of business in Washington D.C., is not a citizen of any state for diversity purposes, and the plaintiff, a New York citizen, failed to establish complete diversity. Judge Menashi dissented.

Schneiderman v. American Chemical Society - Diversity Jurisdiction

The Second Circuit affirmed dismissal of plaintiff Arnold Schneiderman's disability discrimination suit against the American Chemical Society, holding that 28 U.S.C. § 1332(c)(1) does not establish diversity jurisdiction for federally chartered corporations. The court ruled that the statute's principal-place-of-business provision applies only to state-incorporated corporations, not federally chartered entities.