Hertz Corp. v. Friend

Facts

In September 2007, Melinda Friend and John Nhieu, two California citizens, sued the Hertz Corporation in a California state court. They claimed Hertz had violated California's wage and hour laws. They asked for damages and sought relief for a potential class of California citizens who had allegedly suffered similar harms. Hertz filed a notice to remove the case to federal court. It argued that the parties were citizens of different States, so the federal court had diversity jurisdiction (power to hear suits between citizens of different States). Friend and Nhieu answered that Hertz was a California citizen, like themselves, so diversity was missing. Hertz supported its position with a declaration from an employee relations manager. The declaration said Hertz operated facilities in 44 States. California accounted for 273 of its 1,606 car rental locations, about 2,300 of its 11,230 full-time employees, about $811 million of its $4.371 billion in annual revenue, and about 3.8 million of its roughly 21 million annual rentals. The declaration also said Hertz's leadership sat at its corporate headquarters in Park Ridge, New Jersey. Its core executive and administrative functions were carried out there and, to a lesser extent, in Oklahoma City, Oklahoma.

Issues

1. Does the Court have jurisdiction to review the Court of Appeals' decision on a remand order, given that the statute allowing the appeal refers only to courts of appeals and sets a 60-day limit?
2. Under the diversity statute, 28 U.S.C. § 1332(c)(1), what does a corporation's "principal place of business," and therefore its State citizenship, refer to?

Holding

The Court has jurisdiction to review the case. A corporation's "principal place of business" is its nerve center, where its officers direct, control, and coordinate its activities, not the State where it does the most business. The Court vacated the Ninth Circuit's judgment and remanded.