Monday, October 28, 2019

Diversity Jurisdiction and Labor Unions

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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