J.A. Olson Co. v. City of Winona
United States Court of Appeals for the 5th Circuit
818 F.2d 401 (5th Cir. 1987)
Olson (plaintiff), incorporated in Illinois and headquartered there, sued the City of Winona, Mississippi (defendant), asserting diversity jurisdiction. Olson's only manufacturing plant was in Mississippi, where it also made key employment, production, and account-management decisions, kept its bank accounts, and belonged to local business organizations it did not join elsewhere; its Illinois headquarters made executive-level decisions, but based on information generated in Mississippi. The district court found Olson's real principal place of business was Mississippi — the same state as the defendant — destroying diversity, and dismissed the case for lack of jurisdiction.
Whether a corporation's principal place of business, for diversity purposes, is the state in which, given the totality of the circumstances, it predominantly operates and makes managerial decisions, even if it is headquartered in a different state.