United Steelworkers of America v. R. H. Bouligny, Inc.

15 L. Ed. 2d 217 · Supreme Court of the United States · 1965

Facts

A North Carolina corporation sued the United Steelworkers, an unincorporated union, for defamation in state court. The union removed the case to federal court, asserting diversity jurisdiction by claiming it was a citizen of Pennsylvania, despite having North Carolina members. The corporation argued that an unincorporated association's citizenship is determined by all its members, and the District Court retained jurisdiction, but the Court of Appeals reversed.

Procedural history

R. H. Bouligny, Inc. brought the action in a North Carolina state court for defamation. The United Steelworkers removed the case to a Federal District Court, asserting diversity jurisdiction. The District Court retained jurisdiction, but the Court of Appeals for the Fourth Circuit reversed and directed remand to the state courts. The Supreme Court granted certiorari to decide the diversity jurisdiction question.

Issue

The central legal question is whether an unincorporated labor union should be treated as a citizen for purposes of federal diversity jurisdiction, independent of the citizenship of its individual members.

Holding

The Supreme Court affirmed the Court of Appeals' decision, holding that an unincorporated labor union is not to be treated as a citizen for diversity jurisdiction without regard to its members' citizenship, and thus the case should be remanded to state court.

Rule

The Court held that extending federal diversity jurisdiction to new categories of litigants, such as unincorporated associations, is a matter for legislative consideration by Congress, not for judicial amendment, due to the complexities involved and the constitutional role of the judiciary.

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Case brief last reviewed 2026-06-05. Prepared by CaseReader from the published opinion.