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Exxon Mobil Corp. v. Allapattah Services

Supreme Court of the United States · 2005 · Civil Procedure

Civil Proceduresupplemental jurisdiction28 USC 1367diversityamount in controversysupplemental jurisdiction§ 1367(a)§ 1367(b)

Facts

In one case, about 10,000 Exxon dealers brought a diversity class action alleging Exxon systematically overcharged them for fuel, and the district court exercised supplemental jurisdiction over class members whose claims were below the jurisdictional minimum. In the other case, a 9-year-old girl sued Star-Kist in diversity after suffering severe injuries from a tuna can, and her family joined with related claims for emotional distress and medical expenses. The First Circuit concluded the girl met the amount-in-controversy requirement but her family members did not. The legal dispute in both cases was whether § 1367 allowed federal jurisdiction over those additional plaintiffs' related claims despite their failure to meet the statutory amount.

Issue

In a diversity action, may a federal court exercise supplemental jurisdiction under 28 U.S.C. § 1367 over additional plaintiffs whose claims do not independently satisfy the amount-in-controversy requirement, when at least one named plaintiff's claim does satisfy that requirement and the claims are part of the same Article III case or controversy? More specifically, does such a case qualify as a "civil action of which the district courts have original jurisdiction" within the meaning of § 1367(a)?

Rule

Where the other elements of diversity jurisdiction are present and at least one named plaintiff in the action satisfies the amount-in-controversy requirement, § 1367(a) authorizes supplemental jurisdiction over other plaintiffs' claims that are part of the same Article III case or controversy, even if those claims are for less than the jurisdictional amount, unless a specific exception in § 1367(b) applies. A defect in amount in controversy is claim-specific and does not destroy original jurisdiction over the entire civil action, unlike a failure of complete diversity, which contaminates all claims.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nina Patel of Illinois and Omar Reed of Illinois sued Blue Mesa Equipment, Inc., a corporation incorporated and headquartered in Colorado, in federal court in Chicago after the same warehouse hoist collapsed during a delivery. Nina seeks $180,000 for severe physical injuries, while Omar seeks $20,000 for lost tools and minor medical expenses.

Assuming both claims arise from the same Article III case or controversy and no statutory exception applies, may the federal court hear Omar's claim?

Explanation. The majority held that when the other elements of diversity jurisdiction are present and at least one named plaintiff satisfies the amount-in-controversy requirement, § 1367(a) permits supplemental jurisdiction over other plaintiffs' related claims that are part of the same Article III case or controversy, unless § 1367(b) withdraws it. A shortfall in amount in controversy is claim-specific and does not destroy original jurisdiction over the civil action.