In a February 23, 2010 case, Hertz Corp. v. Friend, the United States Supreme Court took up the issue of forming a simpler test to determine a corporation’s citizenship for purposes of diversity jurisdiction. The diversity jurisdiction statute states “a corporation shall be deemed to be a citizen of any State by which it has been incorporated and of the State where it has its principal place of business.” 28 U.S.C. § 1332(c)(1) (emphasis added). Prior to this case, there was not a uniform interpretation used among the federal courts to determine this issue of corporate state citizenship.
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