Patch v. Wabash Railroad

Background

A man sued a railroad company after his relative died in a collision on the railroad in Illinois. The railroad asked to move the case from the Illinois court to a federal court, saying it was a citizen of Ohio. The plaintiff then filed a formal plea saying the railroad was organized under Illinois law (along with other States) and that he was actually an Ohio citizen, and asked whether the federal court could hear the case.

Reasoning

The trial judge first certified that the record showed the railroad was not an Illinois citizen, allowing removal, but later tried to change that certification. The Court said the attempted change could not be treated as a simple clerical fix. Looking at the plea on the merits, the Court held that the railroad existed and incurred liability under Illinois law and therefore must be treated as an Illinois citizen for this suit. The Court explained that being incorporated or organized elsewhere does not let a company escape litigation in the State where it operates and is sued.

Real world impact

Because the railroad was treated as an Illinois citizen, it had no right to send the case to federal court. The Supreme Court reversed the federal judgment and sent the case back to the Illinois court. The underlying wrongful-death claim remains to be decided in state court, and this ruling resolves only where the case must be heard.