Americold Realty Trust v. ConAgra Foods, Inc., 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified rules for determining whether a federal court may exercise diversity jurisdiction in cases involving unincorporated organizations. The case began as a contract dispute between food producers and a warehouse owner when millions of tons of stored food were destroyed in a warehouse fire. A federal trial court initially ruled in favor of the warehouse owner, but on appeal, the United States Court of Appeals for the Tenth Circuit ruled that the federal district court may not have had jurisdiction. The Tenth Circuit held that the warehouse owner, a real estate investment trust ("REIT"), should be treated as an unincorporated organization and the district court