Friday, December 27, 2013

J.A. Olson Co. v. City of Winona case brief

J.A. Olson Co. v. City of Winona case brief summary
818 F.2d 401 (5th Cir. 1987)

Plaintiff manufacturer sought review of a judgment from the United States District Court for the Northern District of Mississippi, which dismissed plaintiff's claim against defendant city based on lack of diversity jurisdiction.

Plaintiff manufacturer was an Illinois corporation that had its executive offices in Chicago and its sole manufacturing plant in the city of Winona, Mississippi. Plaintiff brought suit in federal court against defendant city, basing jurisdiction on diversity of citizenship. The district court dismissed for lack of jurisdiction on the ground that diversity of citizenship was lacking because plaintiff's principal place of business was in Mississippi.


  • The court affirmed, holding that although plaintiff's nerve center was located primarily in Chicago, this fact did not outweigh the greater significance that Winona was the locale of plaintiff's only substantial activity. 
  • Such activities included significant management decisions, accounts receivable and payable, the location of plaintiff's vast majority of employees, where plaintiff was most visible, where its products were manufactured, where it had its most substantial investment, and where, more than any other place, its corporate purpose was fulfilled. 
  • Winona was therefore plaintiff's principal place of business.

The court affirmed the dismissal of plaintiff manufacturer's claim against defendant city for lack of jurisdiction because diversity of citizenship was lacking where plaintiff's principal place of business was in Mississippi, where defendant was located.

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