Summary of Randazzo v. Eagle-Picher Industries, Inc.
117 F.R.D. 557 (1987)
Facts: P sued some corporations for his injuries caused by asbestos. In his complaint, P failed to list place of incorporation or principal place of business for some of the corporations. P’s amended compalint also failed to provide this information.
Issue: Did the federal court have subject matter jurisdiction based on diversity where the plaintiff fails to provide the place of incorporation or principal place of business of the corporate defendants?
Rationale: A corporation has dual citizenship. For diversity purposes, a corporation is a resident of the place of its incorporation and the place where it has it’s principal business. Both of these places must be diverse from the plaintiff’s residency in order to establish diversity jurisdiction. In this case, the plaintiff failed to provide sufficient information to establish subject matter jurisdiction.
Example: Lets assume that Yahoo Inc. is incorprated in Delaware and it has its principal place on business in California. A plaintiff from Delaware or from California cannot sue Yahoo in a federal court based on diversity jurisdiction.