The Second Circuit Holds That Federally Chartered Corporations Have No Citizenship Under § 1332, Limiting Diversity Jurisdiction

For purposes of diversity jurisdiction under 28 U.S.C. § 1332, is a federally chartered corporation (which is not incorporated in any state) a citizen of the state where it has its principal place of business? In Schneiderman v. American Chemical Society, 172 F.4th 158 (2d Cir. 2026), a divided Second Circuit panel said no, holding that such a corporation has no citizenship at all for purposes of § 1332. Schneiderman creates a split with the Fourth Circuit (in Navy Federal Credit Union v. LTD Financial Services, LP, 972 F.3d 344 (4th Cir. 2020)) and has significant implications for any litigant seeking to bring—or to defeat—a diversity action involving a federally chartered entity.

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