Grupo Dataflux v. Atlas Global Group
Atlas, a Texas partnership, brought suit in a United States district court against Dataflux, a Mexican corporation, for breach of contract. Jurisdiction was based solely on diversity of citizenship. At the time the complaint was filed, Atlas had two Mexican citizens in its partnership. Shortly before trial, however, Atlas completed a business transaction that removed the two Mexican citizens from its partnership. After a jury trial awarded $750,000 in damages to Atlas, Dataflux moved to dismiss for lack of diversity of citizenship at the time the complaint was filed. The motion was granted. The Fifth Circuit Court of Appeals reversed, finding that the jurisdictional defect was cured by the time the parties started trial, that the parties and the court had committed time and resources to the litigation, and that the parties had received the benefit of an impartial jury verdict after a six-day trial.
Question Presented:
When can citizenship in a diversity jurisdiction suit be determined?
