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C. T. Carden, Et Al. v. Arkoma Associates

• 1989 • 494 U.S. 185 • Rehnquist Court
In the case of C. T. Carden, et al. v. Arkoma Associates in 1989, the U.S Supreme Court ruled on whether a limited partnership could be considered a citizen for diversity jurisdiction purposes under federal law. The plaintiffs were partners in Arkoma Associates and had filed suit against other members of their partnership in Oklahoma state court over alleged mismanagement and fraud; however, these defendants successfully moved to have the case transferred to federal court based on diversity...Open Case
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Chief Rehnquist Court
Term: 1989
Docket: 88-1476
494 U.S. 185
110 S. Ct. 1015
108 L. Ed. 2d 157
1990 U.S. LEXIS 1172
Argued: Nov 07, 1989

C. T. Carden, Et Al. v. Arkoma Associates

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Opinion Summary
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In the case of C. T. Carden, et al. v. Arkoma Associates in 1989, the U.S Supreme Court ruled on whether a limited partnership could be considered a citizen for diversity jurisdiction purposes under federal law. The plaintiffs were partners in Arkoma Associates and had filed suit against other members of their partnership in Oklahoma state court over alleged mismanagement and fraud; however, these defendants successfully moved to have the case transferred to federal court based on diversity jurisdiction - which requires that all parties involved are from different states. The issue before the Supreme Court was whether this move was valid given that one of the partnerships involved (Arkoma) included both Oklahoma and out-of-state residents among its members – thus potentially negating complete diversity between parties as required by law. The Supreme Court held that for purposes of determining citizenship under diversity jurisdiction rules, an unincorporated entity such as a partnership is deemed to be a citizen of every state where any partner resides – not just where it has its principal place of business or is registered to do business. This meant that because some partners resided within Oklahoma (the same state as some defendants), there wasn't complete diversity between parties so removal to federal court was improper.

Dissent Summary
AI Abstract

In the dissenting opinion for C. T. Carden, et al. v Arkoma Associates, Justice Brennan disagreed with the majority's decision to deny a limited partnership entity access to federal courts based on diversity jurisdiction solely because one of its partners was not diverse from an opposing party in litigation. He argued that this ruling contradicted previous decisions where corporations were granted such access despite non-diverse shareholders and disregarded modern business realities where partnerships function similarly to corporations. Furthermore, he criticized the court's reliance on 19th-century precedents which did not reflect current legal understandings or practices regarding business entities like limited partnerships.

Opinion written by Justice AScalia
Decided: Feb 27, 1990
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Argued: Oct 05, 2026
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