Carden v. Arkoma Associates

108 L. Ed. 2d 157 · Supreme Court of the United States · 1990

Facts

Arkoma Associates, an Arizona limited partnership, sued Louisiana citizens in federal court, relying on diversity jurisdiction. Defendants moved to dismiss, arguing a limited partner was also a Louisiana citizen, destroying complete diversity. The District Court and Fifth Circuit found complete diversity by considering only the general partners' citizenship.

Issue

The legal question is whether, for diversity jurisdiction purposes, the citizenship of a limited partnership is determined by considering only its general partners, or if the citizenship of all its limited partners must also be taken into account.

Holding

The Supreme Court reversed the Fifth Circuit, holding that the citizenship of all members of a limited partnership, including limited partners, must be considered to determine diversity of citizenship.

Rule

For unincorporated associations, including limited partnerships, diversity jurisdiction depends on the citizenship of all its members, not just the general partners, and such entities cannot be considered citizens in their own right like corporations.

Read the full opinion on CourtListener

Case brief last reviewed 2026-04-18. Prepared by CaseReader from the published opinion.