The fact that, against completely diverse defendants, Woodrock and Jones could combine their claims to meet the amount in controversy is inconsequential, because the parties lack diversity of citizenship.

9. There are several factors that should be taken into consideration in deciding whether the District of Columbia can, for diversity purposes, be regarded as a state. The most important factor is whether the constitutional diversity requirement would have a substantive impact on the litigants seeking redress in a certain type of court. Because citizens of the District of Columbia are already entitled to bring suit in federal courts, allowing them to be considered citizens of a state for the purpose of establishing diversity jurisdiction does not allow them entry into a different court system. Even more important is the fact that the legislature enacted a law that permitted the District of Columbia and other U.S. territories to be treated as...
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