Law360, New York (November 13, 2015, 5:27 PM EST) -- Although master limited partnerships (MLPs) first came into existence in the early 1980s, there has been no definitive guidance from the U.S. Supreme Court or Congress on the method for determining an MLP's citizenship for purposes of diversity jurisdiction. Recently, however, the Tenth Circuit Court of Appeals, in Grynberg v. Kinder Morgan, became the first federal appellate court to examine the MLP structure as it relates to citizenship, and ruled that the citizenship of an MLP consists of each of its individual unitholder's citizenship.[1] In many cases, this may involve tens or hundreds of millions of units owned by individuals across most, if not all, of the 50 states. If the Tenth Circuit's holding in Grynberg is adopted by other circuit courts or the U.S. Supreme Court, federal lawsuits by or against MLPs based on diversity jurisdiction may be few and far between....
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