Case, the interests of
corporations in docketing cases in the federal courts as citizens of
different States appeared more important to the Supreme Court than the
weight to be attached to precedents, even those set by John Marshall,
and in Louisville, Cincinnati, and Charleston R. Co. _v._ Letson,[527]
both the Deveaux and Slocomb cases were overruled. After elaborate
arguments by counsel, the Court, speaking through Justice Wayne, held
that "a corporation created by and doing business in a particular State,
is to be deemed to all intents and purposes as a person, although an
artificial person, an inhabitant of the same State, for the purposes of
its incorporation, capable of being treated as a citizen of that State,
as much as a natural person."[528]

In the Letson Case the emphasis is upon the place of incorporation of a
joint stock company as something completely separate from the
citizenship of its members. In succeeding cases, however, this fiction
of corporate personality has undergone modifications so that a
corporation, though still a citizen of the State where it is chartered,
is such by virtue of the jurisdictional fiction that all the
stockholders are citizens of the State which by its laws created the
corporation.[529] This presumption is conclusive and irrebuttable and
resembles in many ways the English jurisdictional fiction that for
providing remedies for wrongs done in the Mediterranean "the Island of
Minorca was at London, in the Parish of St. Mary Le Bow in the Ward of
Cheap."[530] This fiction creates a logical anomaly, which the Letson
rule had avoided, in those cases in which a stockholder of one State
sues a corporation chartered in another State. Although all stockholders
are conclusively presumed to be citizens of the State where the
corporation is chartered, an individual stockholder from a different
State may nevertheless aver his actual citizenship so as to maintain a
diversity suit against the corporation.[531] These rulings lead to some
extraordinary results, as John Chipman Gray has indicated: "The Federal
courts take cognizance of a suit by a stockholder who is a citizen, say,
of Kentucky, against the corporation in which he owns stock, which has
been incorporated, say, by Ohio. Since he is a stockholder of an Ohio
corporation, the court conclusively presumes that he is a citizen of
Ohio, but if he were a citizen of Ohio, he could not sue an Ohio
corporation in the Federal courts. Therefo