Wachovia Bank, N.A. v. Schmidt

In Wachovia Bank, N.A. v. Schmidt, 546 U.S. 303 (2006), the U.S. Supreme Court ruled that a federally chartered bank (Wachovia) has as its state of citizenship for jurisdictional purposes the state where its main office is located and every state in which it operates.

Justice Ruth Bader Ginsburg wrote the opinion for the unanimous 8-0 Court (Justice Clarence Thomas did not participate). She observed in connection with jurisdiction and venue:

Venue is largely a matter of litigational convenience; accordingly, it is waived if not timely raised. See, e.g., Heckler v. Ringer, 466 U.S. 602, 638, n. 25, 104 S. Ct. 2013, 80 L. Ed. 2d 622 (1984) (Stevens, J., concurring in judgment in part and dissenting in part); Fed. Rule Civ. Proc. 12(h)(1). Subject-matter jurisdiction, on the other hand, concerns a court's competence to adjudicate a particular category of cases; a matter far weightier than venue, subject-matter jurisdiction must be considered by the court on its own motion, even if no party raises an objection. See, e.g., Mansfield, C. & L. M. R. Co. v. Swan, 111 U.S. 379, 382, 4 S. Ct. 510, 28 L. Ed. 462 (1884); Fed. Rule Civ. Proc. 12(h)(3).