Yueh-Lan Wang, by and through her Attorney-in-Fact, Winston Wen-Young Wong v. New Mighty U.S. Trust, et al.

Summary

The D.C. Circuit held that for diversity subject-matter jurisdiction under 28 U.S.C. § 1332(a), a “traditional trust”—one lacking juridical person status under state law—assumes the citizenship of its trustees, not its beneficiaries. Applying *Americold Realty Trust v. ConAgra Foods, Inc.*, the court distinguished traditional trusts from business trusts or other unincorporated entities subject to the “all members” rule of *Carden v. Arkoma Associates*. Because the New Mighty U.S. Trust was a donative trust governed by D.C. law that could not sue or be sued as an entity, it was a traditional trust, and its citizenship was determined by its trustee, Clearbridge LLC, resulting in complete diversity. The court reversed the district court’s dismissal for lack of subject-matter jurisdiction and remanded.

Holdings

1. A traditional trust carries the citizenship of its trustees, not its beneficiaries.
2. The district court erred because it applied the membership test from Carden to a traditional trust; under the correct standard, complete diversity exists.
3. The motion to substitute is granted; the substitution is without prejudice to the defendants' ability to renew their arguments in the district court.

Questions Presented

1. How is citizenship determined for a 'traditional trust' for purposes of diversity subject-matter jurisdiction under 28 U.S.C. § 1332(a)?
2. Whether the district court had subject-matter jurisdiction over this lawsuit, given that New Mighty U.S. Trust is a named defendant.
3. Whether Winston Wen-Young Wong and the joint executors of Yueh-Lan Wang's will should be substituted as parties on appeal.

Disposition

reversed_and_remanded