United States Supreme Court holds Maryland real estate trusts, like all unincorporated associations, have citizenship of all their members; summarily reverses capital murder conviction for Brady violation; and holds Alabama must give full faith and credit to Georgia same sex couple adoption decree.

Americold Realty Trust v ConAgra Foods, Inc.

Trust sued ConAgra and other corporate defendants alleging damages arising out a fire at a warehouse. The 10th Circuit ultimately dismissed for lack of jurisdiction on the grounds that Trust was an unincorporated association and failed to prove diversity of citizenship between its members and the corporate defendants. The Court unanimously affirmed. It held that trust is an unincorporated entity under Maryland law, Trust has the citizenship of its shareholders as unincorporated entities have the citizenship of all its members and Trust failed to prove diversity of citizenship in its pleadings or through other evidence. The Court held that true trusts are relationships between people, that merely labeling something a trust does not make it so and real estate trusts as defined in Maryland statues are entities not relationships. The Court finally noted that it is up to Congress to adopt the same rule for unincorporated entities as exists for corporations not the courts.

Warby v Cain

Warby challenged Louisiana state court’s denial of his post-conviction petition. The Court, 6-2, summarily reversed. The per curium majority held that there was a Brady violation because the withholding of evidence that the state’s main witness testified in retaliation for Warby jacking him over and asked witnesses to lie, evidence that another witness lied about seeking a reduced sentence in exchange for his testimony and evidence that another person could not have physically done the running the main witness testified the person did undermined confidence in the verdict and thus a new trial was necessary. It held that the summary reversal was consistent with past practice and Louisiana had ample opportunity to state its case. Alito, joined by Thomas, dissented arguing the withheld evidence did not undermine confidence in the verdict as the jury had plenty of evidence that the main witness had credibility issues and asked witnesses to lie and the that the person alleged to be incapable of running had knee surgery 9 day before the homicide. He further argued that other evidence such as possessing property of the victim after the murder connected Warby to the crime. He finally greed that Brady case arte fact intensive, summary reversal is this inappropriate and there was plenty of space to hear argument calendar if the majority felt the case should be reviewed.

V.L v E.L.

V.L. sought to enforce a Georgia adoption decree and obtain visitation with the children of her female partner whom she adopted. The Alabama Supreme Court ultimately rejected her request holding Georgia’s district court lacked subject matter jurisdiction and thus the judgment was not entitled to full faith and credit. The Court summarily reversed holding Georgia statute gave subject matter over adoptions to the district courts and this was sufficient to trigger the full faith and credit clause.