As we said before, we love federal court. And yesterday the United States Supreme Court made it easier for us to get there. In Hertz Corporation v. Friend the Court recognized a bright line rule regarding a corporation's principal place of business:
[W]e conclude that the phrase "principal place of business" refers to the place where the corporation's high level officers direct, control, and coordinate the corporation's activities. Lower federal courts have often metaphorically called that place the corporation's "nerve center." See, e.g., Wisconsin Knife Works v. National Metal Crafters, 781 F. 2d 1280, 1282 (CA7 1986); Scot Typewriter Co. v. Underwood Corp., 170 F. Supp. 862, 865 (SDNY 1959) (Weinfeld, J.). We believe that the "nerve center" will typically be found at a corporation's headquarters.
Before this decision, much time was spent comparing and contrasting how much business a corporate defendant had in one state versus another. Now, absent a showing of jurisdictional manipulation, the inquiry is simple:
[T]he courts should instead take as the "nerve center" the place of actual direction, control, and coordination.