In the United States v. United Continental Tuna Corp., 1975, the Supreme Court examined whether a Philippine corporation could be considered a citizen of California under federal diversity jurisdiction rules. The case arose when two Filipino citizens were injured while working on a fishing vessel owned by United Continental Tuna Corporation (UCTC), which was incorporated in the Philippines but had its principal place of business in San Diego, California. They filed suit against UCTC in federal court seeking damages for their injuries under general maritime law and various statutes. The issue before the Supreme Court was whether UCTC could be deemed to have dual citizenship - both in its state of incorporation (the Philippines) and where it has its principal place of business (California). If so, this would allow for diversity jurisdiction to apply as plaintiffs were also foreign citizens. However, Justice Thurgood Marshall writing for majority held that only American corporations can claim dual citizenship status for purposes of diversity jurisdiction; foreign corporations cannot do so even if they have their main office or center of operations within an American state. Therefore, since there wasn't complete "diversity" between parties involved as required by statute governing such cases at that time, federal courts lacked subject matter jurisdiction over this dispute.

In the dissenting opinion for United States v. United Continental Tuna Corp., it was argued that the majority's interpretation of the statute in question, which allowed a private party to sue on behalf of the government and share in any recovery, was incorrect. The dissent contended that this interpretation undermined Congress' intent when passing the law - to encourage private parties to expose fraud against the government by providing them with a financial incentive. They believed that allowing such suits only when they were based on information not already known by the government would discourage potential whistleblowers from coming forward if there was any chance their information had already been discovered. Furthermore, they disagreed with limiting these suits to cases where fraud resulted in economic injury to the U.S., arguing this ignored other types of harm caused by fraudulent conduct.