In the case of Cannon Manufacturing Company v. Cudahy Packing Company, the U.S. Supreme Court ruled in 1924 that a corporation cannot be considered a resident of a state simply because it has an agent operating within that state's borders. The court held that for purposes of federal diversity jurisdiction, which allows cases to be heard in federal court if they involve citizens from different states, corporate citizenship is determined by where the company is incorporated and where its principal place of business is located. In this case, Cudahy was incorporated and had its main office in Illinois but also operated through an agent in North Carolina; however, this did not make it a citizen of North Carolina according to the Court’s ruling.

The dissenting opinion in the case of Cannon Manufacturing Company v. Cudahy Packing Company argued that a corporation should not be considered as having presence in a state simply because it has an agent operating there, especially if the agent's activities are limited and do not involve property ownership or contracts made within the state. The dissent emphasized that corporations must have some degree of permanence and continuity within a jurisdiction to be deemed present for legal purposes. It was also suggested that allowing such broad interpretation could lead to potential abuses where corporations might be dragged into court in states where they have minimal connections, which would undermine principles of fair play and substantial justice.