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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).

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