Grupo Dataflux v. Atlas Global Group, L.P.
Supreme Court
541 U.S. 567 (2004)
Atlas Global Group (plaintiff), a Texas limited partnership, sued Grupo Dataflux (Dataflux) (defendant), a Mexican corporation, in federal court based on diversity jurisdiction, and a jury awarded Atlas $750,000. Before judgment was entered, Dataflux moved to dismiss, revealing that at the time of filing some of Atlas's partners were Mexican citizens - meaning aliens appeared on both sides of the case, destroying complete diversity. By the time of trial, Atlas's Mexican partners had left the partnership, restoring diversity, and the Fifth Circuit, relying on Caterpillar Inc. v. Lewis, reversed the district court's dismissal on that basis.
Whether a federal court's lack of subject-matter jurisdiction at the time of filing, due to a lack of complete diversity, can be cured by a party's post-filing change in citizenship.