U.S. Bank Trust, N.A. v. Dedoming
Docket: CIVIL ACTION NO. 17–10616–WGY
Court: District Court, District of Columbia; April 10, 2018; Federal District Court
The court addressed the issue of diversity jurisdiction in a foreclosure case involving the LSF9 Trust. The Defendants attempted to argue that the citizenship of the LSF9 Trust might be Massachusetts, which would negate diversity jurisdiction under 28 U.S.C. § 1332(a). The court examined whether a business trust's citizenship is determined by the citizenship of its trustees or beneficiaries. It established that, traditionally, a trust's citizenship is based on its trustees. For business trusts, citizenship can depend on whether the trustee is a corporation or an unincorporated entity. If unincorporated, diversity is assessed based on the citizenship of all members. The court referenced the U.S. Supreme Court's ruling in Americold Realty Trust v. Conagra Foods, clarifying that if the trustee is a party to the litigation, the trustee's citizenship controls. Conversely, when the trust itself is involved, the citizenship derives from all its members. In this case, U.S. Bank Trust, N.A., as the trustee for the LSF9 Master Participation Trust, was acting on behalf of the trust. Therefore, its citizenship determined the diversity analysis, confirming that the court possesses jurisdiction. The court concluded that the foreclosure process is valid, acknowledging damages related to a claim of use and occupancy amounting to $1,800. The proposed order by the Plaintiff was approved and ordered accordingly.