Exxon Mobil Corp. v. Allapattah Services, Inc.

Brief Fact Summary.

Two cases were consolidated to resolve a circuit split regarding the application of the joinder to the amount in controversy requirement of diversity jurisdiction.

Synopsis of Rule of Law.

When all the other elements of diversity jurisdiction are met and at least one of the plaintiffs satisfies the amount in controversy requirement, the claims of other plaintiffs may be properly joined even if their damages do not meet the amount in controversy requirement.

Facts.

Consolidation of two cases to resolve circuit split regarding amount in controversy in diversity jurisdiction cases. Some of the class members’ claims did not meet the amount in controversy requirement for diversity jurisdiction, but the Eleventh Circuit Court of Appeals allowed joinder of the claims and allowed the case to proceed so long as one of the claims met the amount in controversy requirement. The second case involved a young girl that sued Starkis for an injury she sustained when she cut herself on one of their cans. The girl attempted to join her parents as Plaintiffs but the district court held that none of the parties had damages that met the amount in controversy requirement. On appeal, the First Circuit found that the parents’ claims did not meet the requirement and therefore could not be joined, but that the girl’s claim was and could be brought on its own. The United States Supreme Court granted certiorari to resolve the circuit split.

Issue.

When all the other elements of diversity jurisdiction are met and at least one of the plaintiffs satisfies the amount in controversy requirement, may the claims of other plaintiffs be properly joined even if their damages do not meet the amount in controversy requirement?

Held.

Yes, When all the other elements of diversity jurisdiction are met and at least one of the plaintiffs satisfies the amount in controversy requirement, the claims of other plaintiffs may be properly joined even if their damages do not meet the amount in controversy requirement. The holding of the Court of Appeals is affirmed and the holding of the Court of Appeals for the First Circuit is reversed and the case is remanded.

Dissent.

Justice Justice Ginsburg with Justices Stevens, O’Connor, and Breyer dissenting

The majority read § 1367 too broadly. Congress did not intend to enlarge the jurisdiction of federal courts with § 1367. The court should have read § 1367 as requiring the plaintiffs to first satisfy the amount in controversy before the court could exercise supplemental jurisdiction. The court’s reading of § 1367 completely ignores the history of supplemental jurisdiction.

Discussion.

1. The court must decide whether, under 28 U.S.C. § 1367, the court may exercise jurisdiction over other plaintiffs that may be properly joined, but whose damages do not reach the amount in controversy threshold.
2. This court finds that they can.
3. Some parties may be required to be joined under FRCP 19, so to allow the claim to be dismissed because the amount in controversy is not satisfied is illogical.
4. The holding of the Court of Appeals is affirmed and the holding of the Court of Appeals for the First Circuit is reversed and the case is remanded.