Woods v. U.S. Bank, N.A.

A homeowners association’s post-foreclosure quiet title action stated a viable claim against the former owner who might challenge the foreclosure; hence, the former owner was not fraudulently joined and the federal courts lacked diversity jurisdiction.  Under Oregon’s Deed of Trust Act, a borrower may bring a post-foreclosure suit to overturn a non-judicial sale only for…

Americold Realty Trust v. ConAgra Foods, Inc.

Though it bears the label “trust,” a real estate investment trust is a separate legal entity which can sue and be sued; so for diversity purposes, it is a citizen of every state of which any of its members is a citizen. For diversity purposes, a legal entity’s citizenship is determined by the citizenship of…