Bank of the United States v. Deveaux
"Bank of the United States v. Deveaux" is a significant Supreme Court case that addresses the legal principles surrounding diversity jurisdiction, particularly in relation to corporate entities. The case arose when the Bank of the United States sought to recover property through a lawsuit against a Georgia tax collector. Central to the dispute was whether the bank, as a corporation, could pursue this case in federal court, given that some of its shareholders were residents of Georgia. The Supreme Court ruled unanimously that the bank could not sue in federal court under diversity jurisdiction due to these connections, setting a precedent that restricted corporate access to federal courts in similar situations.
This ruling highlighted the complexities of corporate citizenship and its implications for legal proceedings. The limitations imposed by this decision were later overturned by the 1844 case "Louisville, Cincinnati, and Charleston Railroad Co. v. Letson," which acknowledged that corporations have citizenship in the state that grants their charter, thereby expanding their ability to engage in federal lawsuits. The evolution of these legal interpretations reflects ongoing discussions about the rights and responsibilities of corporations within the judicial system.
Bank of the United States v. Deveaux
Date: March 15, 1809
Citation: 5 Cranch (9 U.S.) 61
Issue: Citizenship of corporations
Significance: The Supreme Court held that although a corporation was a citizen for the purpose of diversity jurisdiction, the location of its citizenship was determined by the citizenship of its shareholders.
The Bank of the United States attempted to sue a Georgia tax collector for recovery of property. The issue was whether the bank (as a corporation) could sue in federal court under diversity of citizenship jurisdiction. The Supreme Court’s unanimous ruling made the suit impossible, because some of the bank’s shareholders lived in Georgia. The Deveaux restriction on diversity jurisdiction was overruled in Louisville, Cincinnati, and Charleston Railroad Co. v. Letson (1844), which recognized corporate citizenship in the state granting the charter.
