This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.
In brief
Overview
Petitioner JPMorgan Chase Bank argues that the term “citizens and subjects” applies to corporations, not just natural persons.
According to United States, the United States, as amicus, submits that corporations organized under United Kingdom overseas territories are citizens or subjects of a foreign state for alienage diversity jurisdiction.
According to MR. ALBERT, respondent argues that a British Virgin Islands corporation should not be subject to diversity jurisdiction because its shareholders have opted for BVI status rather than British status.
Background and question before the Court
Oral argument before the Supreme Court began at 11:02 a.m.
Chief Justice Rehnquist asked: “Is this a question of Federal law?”
Chief Justice later asked: “You’re now relying on English law, I take it?”
A Justice asked: “Does it make them subject—subjects?”
A Justice asked: “How does that affect a corporation?”
A Justice asked about Canadians: “Until Canada domesticated its constitution… were they not subjects of the Crown?”
- [1] c4c607e46c456f73b21f-r1-2e96706a298b193d.pdf, p. 1
- [2] c4c607e46c456f73b21f-r1-2e96706a298b193d.pdf, p. 4
- [3] c4c607e46c456f73b21f-r1-2e96706a298b193d.pdf, p. 19
- [4] c4c607e46c456f73b21f-r1-2e96706a298b193d.pdf, p. 24
- [5] c4c607e46c456f73b21f-r1-2e96706a298b193d.pdf, p. 36
- [6] c4c607e46c456f73b21f-r1-2e96706a298b193d.pdf, p. 38
What each side argues
JPMorgan Chase Bank (Petitioner)
According to JPMorgan Chase Bank, petitioner argues that the term “citizens and subjects” applies to corporations, not just natural persons.
According to MS. REID, petitioner’s counsel, Ms. Reid, states that corporations are incorporated under the laws of their legislative district.
United Kingdom (Respondent)
According to United Kingdom, the United Kingdom points out that the British Nationality Act distinguishes classes of citizens and subjects, and that the corporation does not automatically become a citizen or subject of the United Kingdom.
United States (Amicus)
According to United States, the United States submits that corporations organized under United Kingdom overseas territories are citizens or subjects of a foreign state for alienage diversity jurisdiction.
Traffic Stream (BVI Infrastructure Limited) (Respondent)
According to MR. ALBERT, counsel argues that a British Virgin Islands corporation should never be subject to diversity jurisdiction because its shareholders have opted for BVI status rather than British status.
What happened at oral argument
The Supreme Court heard oral argument for this case at 11:02 a.m.
Chief Justice Rehnquist asked whether the issue presented a question of Federal law.
Subsequent questions addressed whether English law applied, whether the corporation was a “subject,” and how the issue affected corporations and other foreign nationals.
What the Court decided
Why it matters
Terms to know
No glossary terms are available for this guide.
Primary sources
Read the source materials on the official site or open the immutable repository copy used for this guide.
- c4c607e46c456f73b21f-r1-2e96706a298b193d.pdforal argument transcript
Guide generated September 19, 2026. Automated validation accepted this version.