Establishing Citizenship of Corporation Under “Nerve Center” Test May Require Fact-Intensive Inquiry

April 04, 2011
The Eastern District of Pennsylvania recently held that under the Supreme Court’s “nerve center” test, GlaxoSmithKline LLC’s principal place of business for diversity purposes is Pennsylvania, even though the company had reconstituted itself as a Delaware LLC with only Delaware members. This update reviews the court’s decision in Brewer v. SmithKline Beacham Corp., 2011 WL 1103627 (E.D. Pa. Mar. 24, 2011).