Americold Logistics, LLC, v. Conagra Foods, Inc.
The Supreme Court of the United States clarified rules for determining whether a federal court may exercise diversity jurisdiction in cases involving unincorporated organizations.
577 U.S. 378 · No. 14-1382 · 2015 term · Roberts Court
Decided Mar 7, 2016 · argued Jan 19, 2016
Judicial power · Miscellaneous judicial power, especially diversity jurisdiction
Majority opinion: Sonia Sotomayor
The voteMajority
8–08 in the majority, 0 in dissent
No dissent (9–0)
Affirmed. Americold Logistics, LLC, lost.
What this ruling means
Affirmed: the Supreme Court upheld the decision of the U.S. Court of Appeals, Tenth Circuit, so it stands (sometimes with changes the Court made to it).
Americold Logistics, LLC, was the petitioner, the side that asked the Supreme Court to review the case. “Lost” means the Court did not give that side the result it asked for.
From the Supreme Court Database. A justice who agreed with the result but not the reasoning counts in the majority.
Summary
The opening of the case’s Wikipedia article: what the case was about and what the Court held.
Americold Realty Trust v. ConAgra Foods, Inc., 577 U.S. 378 (2016), was a case in which the Supreme Court of the United States clarified rules for determining whether a federal court may exercise diversity jurisdiction in cases involving unincorporated organizations. The case began as a contract dispute between food producers and a warehouse owner when millions of tons of stored food were destroyed in a warehouse fire. A federal trial court initially ruled in favor of the warehouse owner, but on appeal, the United States Court of Appeals for the Tenth Circuit ruled that the federal district court may not have had jurisdiction. The Tenth Circuit held that the warehouse owner, a real estate investment trust ("REIT"), should be treated as an unincorporated organization and the district court should not be allowed to exercise diversity jurisdiction without examining the citizenship of the members of the real estate investment trust. The warehouse owner appealed to the Supreme Court, which granted certiorari to resolve a circuit split "regarding the citizenship of unincorporated entities."
Writing for a unanimous Court, Justice Sonia Sotomayor held that for the purposes of diversity jurisdiction, the citizenship of a real estate investment trust should be determined by the citizenship of its shareholders when the real estate investment trust is "held and managed for the benefit and profit of any person who may become a shareholder". Although some commentators have suggested that the Court's ruling is "unlikely to have any broad or long-term impact", others have stated that the Court's ruling "means that REITs like Americold will have a much harder time getting (or keeping) their cases in federal court."
Data notes
The text is Wikipedia’s (CC BY-SA 4.0), matched to the case by its citation, docket number or name and year, and is not checked against the opinion. The site keeps the article’s opening section, ending on its last full sentence. The one-sentence summary under the title is the Decisions list’s: Wikipedia’s own ruling sentence, or, tagged “AI-written”, one Claude wrote from this opening.
How the justices voted
Each justice who took part, placed by their Martin–Quinn ideology score for the 2015 term. Filled: the 8 in the majority. Hollow: the 0 in dissent. Colour is the party of the president who appointed them.
Majority(8)
Sonia SotomayorWrote the majority opinion
Ruth GinsburgJoined the majority
Elena KaganJoined the majority
Stephen BreyerJoined the majority
Anthony KennedyJoined the majority
John RobertsJoined the majority
Samuel AlitoJoined the majority
Clarence ThomasJoined the majority
Dissent(0)
- None.
Data notes
Each justice’s vote and what they wrote are from the justice-centered file of the Supreme Court Database. “Wrote a concurrence” means the justice sided with the majority and wrote separately; a justice who dissented in part is counted on the side they took overall. A justice who wrote nothing is listed as joining their side.
Positions are each justice’s Martin–Quinn score for the case’s term, the same scores as the Ideology page: negative is more liberal, positive more conservative. A score sums up a justice’s votes across the whole term, so it says where they usually sit, not why they voted as they did here. The median line is the Court’s median justice that term.
The parties
Who brought the case to the Court, who answered it, and how it got there.
- Petitioner
- Americold Logistics, LLC,Agent, fiduciary, trustee, or executor
- Respondent
- Conagra Foods, Inc.Food, meat packing, or processing company, stockyard
- Reached the Court by
- Certiorari (the Court chose to hear it)
- Why it was taken
- Federal courts were unsure how to apply the law
Data notes
The names are the two sides of the case’s title. The description under each is the Supreme Court Database’s category for that party, in its own wording. The petitioner is the side that asked the Supreme Court to review the decision below. “Why it was taken” appears only when the majority opinion says lower courts disagreed or were unsure about the question; reasons that would fit any case (“to resolve the question presented”, “an important question”) are left out.
The law at issue
The law the Court was asked to apply, and the kind of power it used to decide.
- Provision
- Article III, Section 2, Paragraph 1 (case or controversy requirement)
- Kind of law
- Constitution
- Decided by
- Diversity jurisdiction
Data notes
The Supreme Court Database codes the main constitutional provision, statute or court rule each case turned on, and the basis of the decision: judicial review of a federal or state law, interpreting a statute, supervising the lower courts, and so on. A case can rest on more than one. “Overruled” counts only where the majority opinion says so.
Timeline
What happened at the Court and how the case got there, newest first.
- Mar 7, 2016DecidedDecided · Decided 8–0: affirmed. Americold Logistics, LLC, lost.
- Jan 19, 2016ArguedArgued · Oral argument before the Court.
- Not datedTaken upTaken up · The Supreme Court agreed to hear the case (certiorari). Federal courts were unsure how to apply the law.
- Not datedCourt belowCourt below · Decided by the U.S. Court of Appeals, Tenth Circuit: vacated and remanded.
- Not datedBeganBegan · The case began in the Kansas U.S. District Court.
Data notes
From the Supreme Court Database: the court the case began in, the court whose decision the Supreme Court reviewed and what that court did, how the case came to the Court, and the dates of argument and decision. The database does not date the steps in the lower courts. Court names are the database’s.
Other decisions on the same issue
9 other argued cases since 1946 on miscellaneous judicial power, especially diversity jurisdiction, newest first.
- The Hain Celestial Group v. Palmquist607 U.S. 421Feb 24, 2026 · 607 U.S. 421Judicial power9–0Unanimous band
- Water Splash, Inc. v. Menon137 S. Ct. 1504May 22, 2017 · 137 S. Ct. 1504Judicial power8–0Unanimous band
- The Hertz Corporation v. Melinda Friend et al.559 U.S. 77Feb 23, 2010 · 559 U.S. 77Judicial power9–0Unanimous band
- Franconia Associates, et al. v. United States536 U.S. 129Jun 10, 2002 · 536 U.S. 129Judicial power9–0Unanimous band
- National City Bank of New York v. Republic of China et al.348 U.S. 356Mar 7, 1955 · 348 U.S. 356Judicial power4–36–3 band
- Lumbermen's Mutual Casualty Co. v. Elbert348 U.S. 48Dec 6, 1954 · 348 U.S. 48Judicial power8–0Unanimous band
- Madruga v. Superior Court of California, in and for the County of San Diego346 U.S. 556Jan 18, 1954 · 346 U.S. 556Judicial power7–27–2 band
- National Mutual Insurance Co. v. Tidewater Transfer Co., Inc.337 U.S. 582Jun 20, 1949 · 337 U.S. 582Judicial power5–45–4 band
- Cope v. Anderson, Receiver331 U.S. 461Jun 2, 1947 · 331 U.S. 461Judicial power8–0Unanimous band
Data notes
Every other orally argued case with a clear vote, from the 1946 term on, that the Supreme Court Database files under the same issue as this one. The database gives each case one issue from a list of about 270 (abortion, search and seizure of vehicles, the death penalty, and so on), whatever law it turned on.
Official record
Read the full opinion on Justia, the argument audio on Oyez and Wikipedia. Case data from the Supreme Court Database, Version 2026 Release 01, through the 2025 term.