Diversity Issue: A National Bank Is Located Where Its Main Office Is.

Plaintiffs, citizens of California, filed an action against a bank in the California superior court. The bank’s main office is in South Dakota and its principal place of business is in California. The bank removed the action to a federal district court, asserting subject matter jurisdiction on the basis of federal questions and diversity of citizenship. Following an order to show cause why the case should not be remanded to state court for lack of diversity jurisdiction, the district court held that national banks are citizens of the state where their principal place of business is located as well as of the state where their main office is located as designated in their articles of association. The district court remanded the case back to the California superior court. Under 28 U.S.C. § 1348, national banking associations are “citizens of the States in which they are respectively located.” The Ninth Circuit reversed, stating: “We conclude that under § 1348, a national bank is ‘located’ only in the state designated as its main office.” (Rouse v. Wachovia Mortgage, FSB (Ninth Circuit; March 27, 2014)747 F.3d 707.)