In Windward Bora v. Browne, 110 F.4th 120 (2d Cir. 2024), the U.S. Court of Appeals for the Second Circuit considered whether the state domiciles of an LLC's permanent resident members are relevant to determining diversity jurisdiction. In a unanimous opinion authored by Circuit Judge John M. Walker Jr. and joined by Circuit Judges Steven J. Menashi and William J. Nardini, the Second Circuit held that state domicile is relevant, and therefore there is no diversity jurisdiction in a suit between U.S. citizens and unincorporated associations with permanent resident members if such jurisdiction would not exist in a suit between the same U.S. citizens and those permanent resident members as individuals. In so holding, the Second Circuit resolved a divide between district courts in the Second Circuit on this question. Going forward, parties to cases involving unincorporated associations can seek to defeat diversity jurisdiction by pointing to the state domicile of the association's permanent resident members, irrespective of those members' national citizenship.