1 Analyses of this case by attorneys

  1. Second Circuit Holds a National Bank’s Citizenship Is Determined Exclusively by Location of Main Office, Not Principal Place of Business

    Shearman & Sterling LLPJaculin AaronJuly 12, 2016

    The Supreme Court, however, left open whether a national bank might also be considered a citizen of the State of its principal place of business, if its principal place of business were located in a different State than its main office, observing that such treatment would be necessary to achieve jurisdictional parity between national and state-chartered banks. In OneWest Bank, N.A. v. Melina, No. 15-3063, 2016 WL 3548346 (2d Cir. June 29, 2016), the Second Circuit agreed with the other Circuit Courts to have considered that question post-Wachovia and held that a national bank is a citizen only of the State listed in its articles of association as its main office, and not also of any other State where it may have its principal place of business. In so holding, the OneWest Court rejected the notion that the concept of jurisdictional parity should be read into the relevant statutes.