The U.S. Supreme Court decided two cases today:
- Hertz Corp. v. Friend, No. 08-1107. For purposes of the federal diversity jurisdiction statute at 28 U.S.C. §1332(c)(1), a corporation’s “principal place of business” is where a “corporation’s high level officers direct, control, and coordinate the corporation’s activities,” sometimes called the corporation’s “nerve center,” which is typically the corporation’s headquarters. The diversity jurisdictional statute specifies that a corporation has citizenship in the state in which it has its principal place of business, as well as its state of incorporation.
- Florida v. Powell, No. 08-1175. A police officer’s explanation to a suspect prior to custodial interrogation that he had a right to talk to a lawyer before answering questions, and that he could use any of his rights at any time during the interview, satisfied Miranda v. Arizona even though the officer did not expressly state that the defendant was entitled to have the lawyer present during questioning. The court also decided that the contrary ruling of the Florida Supreme Court below was not based on an “adequate and independent state ground” just because that court said its ruling was based on the state constitution as well as Miranda.