Schneiderman v. American Chemical Society

── Schneiderman v. American Chemical Society ── Case No.: 21-2737 Court: Court of Appeals for the Second Circuit Date: April 06, 2026 Category: General 21-2737(L) Schneiderman v. American Chemical Society In the United States Court of Appeals for the Second Circuit AUGUST TERM 2024 Nos. 21-2737(L), 24-274(CON) ARNOLD SCHNEIDERMAN, AKA MOSHE SCHNEIDERMAN, Plaintiff-Appellant, v. THE AMERICAN CHEMICAL SOCIETY, Defendant-Appellee. * __________ On Appeal from the United States District Court for the Eastern District of New York __________ ARGUED: MAY 5, 2025 DECIDED: APRIL 6, 2026 ________________ Before: RAGGI, MENASHI, and MERRIAM, Circuit Judges. ________________ Plaintiff, a citizen of New York, invoked diversity jurisdiction to sue defendant, a federally chartered corporation with its principal place of business in * The Clerk of Court is respectfully directed to amend the official case caption as set forth above. Washington, D.C., for disability discrimination in violation of New York State law. Plaintiff now appeals from (1) a judgment of the United States District Court for the Eastern District of New York (Mauskopf, J.) dismissing his action for lack of subject matter jurisdiction, and (2) a subsequent order of the same court declining to reconsider that judgment and to reopen the case for further discovery as to a possible federal law claim. Plaintiff argues that the district court erred in failing to recognize that, even though defendant, as a federally chartered corporation, is not incorporated under the laws of any State, diversity jurisdiction was established under the principal-place-of-business provision of 28 U.S.C. § 1332(c)(1). That provision, however, is properly read to apply not independently, but only in conjunction with the statute’s State-of-incorporation provision, such that a corporation is a citizen not only of the State of its incorporation but also of the State where it has its principal place of business. That reading comports with Congress’s purpose to narrow diversity jurisdiction in cases involving State- chartered corporations. In sum, § 1332(c)(1) does not pertain to federally chartered corporations, such as defendant, that are not incorporated by any State. Thus, the district court correctly concluded that diversity jurisdiction was not established in this case and properly ordered dismissal. As for plaintiff’s other challenges, the district court acted within its discretion in declining both to reconsider its prior rulings and to reopen the case. AFFIRMED. Judge Menashi dissents in a separate opinion. 2  _________________ JOSHUA FULD NESSEN, The Maddox Law Firm, LLC, Weston, CT, for Plaintiff-Appellant. JOSEPH J. LYNETT (Sydney A. Mendelsohn, on the brief), Jackson Lewis P.C., New York, NY, for Defendant- Appellee. _________________ REENA RAGGI, Circuit Judge: Plaintiff Arnold Schneiderman, a citizen of New York, invoked diversity jurisdiction to sue defendant The American Chemical Society (“ACS”), a federally chartered corporation, in the United States District Court for the Eastern District of New York (Roslynn R. Mauskopf, Judge) for alleged disability discrimination in violation of New York State law. See Third Am. Compl. ¶¶ 4, 45 (citing 28 U.S.C. § 1332(a)(1)), Rumain et al. v. Am. C