Diversity Jurisdiction and Labor Unions
A recent decision from Indiana repeated the rule
with respect to the citizenship of labor unions and other unincorporated membership
associations for purposes of federal diversity jurisdiction. IUE-CWA, Local 901 v. Spark Energy, LLC,
Case No. 1:19-CV-00389-HAB-SLC, 2019 WL 5206067 (N.D. Ind. Oct. 16, 2019).
Labor unions, being unincorporated membership
associations, will be deemed to have the citizenship of each of the
participants therein. As set forth by this decision:
Similar to the
citizenship of an LLC, a membership association such as a “a labor union has
the citizenship of every member” of the association. Fellowes, Inc. v. Changzhou Xinrui Fellowes Office Equip. Co., 759
F.3d 787, 788 (7th Cir. 2014) (citing
United Steelworkers of America v. R.H. Bouligny, Inc., 382 U.S. 145
(1965)).
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