SCOTUS holds that national banks are citizens of states where their office is located

Lots of attention has been paid to the assisted suicide case decided last week. However, a day after that case SCOTUS decided a major case dealing with federal-court diversity jurisdiction. The case is styled Wachovia Bank v. Schmidt.

The suit began when citizens of South Carolina sued Wachovia in a South Carolina state court for fraudulently inducing them to participate in an illegitimate tax shelter. Shortly thereafter, Wachovia filed a petition in the United States District Court for the District of South Carolina, seeking to compel arbitration of the dispute. As the sole basis for federal-court jurisdiction, Wachovia alleged the parties' diverse citizenship. The District Court denied Wachovia's petition on the merits; neither the parties nor the court questioned the existence of federal subject-matter jurisdiction. On appeal, a divided Fourth Circuit panel determined that the District Court lacked diversity jurisdiction over the action; it therefore vacated the judgmentand instructed the District Court to dismiss the case. In the Fourth Circuit, a panel essentially held that for purposes of federal-court diversity jurisdiction, a national bank is a citizen of every State in which it has established a branch. Hence, Wachovia could not claim that it was a citizen of North Carolina when it had myriad offices in South Carolina.

SCOTUS reversed, holding that

a national bank, for section 1348 purposes, is a citizen of the State in which its main office, as set forth in its articles of association, is located. Were we to hold, as the Court of Appeals did, that a national bank is additionally a citizen of every State in which it has established a branch, the access of a federally chartered bank to a federal forum would be drastically curtailed in comparison to the access afforded state banks and other state-incorporated entities. Congress, we are satisfied, created no such anomaly.