Thomas v. Board of Trustees of the Ohio State University
Headline: Case about land title and federal diversity: Court ruled a state university board is not a corporation for diversity purposes, refused to presume trustees' citizenship, but allowed pleading amendments to show jurisdiction.
Holding: The Court held that the Board of Trustees of the Ohio State University is not a corporation for federal diversity jurisdiction, that the complaint did not prove trustees' citizenship, and that amendment to allege it may be allowed.
- Means federal courts cannot treat the university board as a corporate citizen for diversity jurisdiction.
- Requires plaintiffs to allege each trustee's state citizenship or amend their pleadings.
- Allows the lower court to permit amendment to show jurisdiction before deciding merits.
Summary
Background
A Michigan citizen sued to partition land he claimed jointly with George Folsom, a California citizen, but the Board of Trustees of the Ohio State University held the land and claimed title. The Board demurred, and the Circuit Court dismissed the bill, finding title in the Board. The Michigan plaintiff and Folsom appealed. The Circuit Court’s power to hear the case depended entirely on whether the parties were citizens of different States.
Reasoning
The Court examined whether the pleadings showed the Board was a corporation of Ohio (which would make its members Ohio citizens for federal purposes), whether the suit could proceed against the Board by its collective name without naming the individual trustees, and whether the trustees’ citizenship could be inferred from the bill. The Court accepted the Ohio Supreme Court’s ruling that the Board was not a corporation but a state agency. It stressed that federal jurisdiction must appear plainly in the record and cannot be established by inference.
Real world impact
The Court answered that the bill did not properly allege the Board was a corporation and did not show the trustees’ citizenship, so jurisdiction did not affirmatively appear. The Court said the suit could proceed in the Board’s name only if the bill were amended to allege each trustee’s Ohio citizenship. The Circuit Court of Appeals may allow such an amendment so the federal court can decide the case on the merits.
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