Exxon Mobile Corp. v. Allapattah Services, Inc.

Brief Fact Summary.

In two separate federal lawsuits, additional plaintiffs to the lawsuit did not meet the amount in controversy requirement under diversity jurisdiction.

Synopsis of Rule of Law.

In a case with multiple plaintiffs, if one plaintiff’s claim meets the amount in controversy requirement for diversity jurisdiction, federal courts may exercise supplemental jurisdiction over substantially related claims from other plaintiffs even if they do not meet the amount in controversy requirement.

Facts.

The current case is a consolidation of two cases, based on a split among Circuit Courts. The first case was brought by about 10,000 dealers (Plaintiffs) of the oil company Exxon Mobile against Exxon Mobile (Defendants) in the District Court for the Northern District of Florida for a scheme to overcharge fuel. Some, but not all, Plaintiffs met the amount in controversy requirement for diversity jurisdiction. The second case was brought by a nine-year-old and her family (Plaintiffs) against Star-Kist (Defendant) in the District Court for the District of Puerto Rico. The girl sued for injuries received from one of the Defendant’s tuna cans, and her family joined the suit seeking damages for emotional distress and medical expenses. The girl, but not her family, met the amount in controversy requirement for diversity jurisdiction.

Issue.

Can a federal court exercise supplemental jurisdiction over plaintiffs’ whose claims do not satisfy theamount in controversy requirement of diversity jurisdiction, if those claims are substantially related to one plaintiff’s claim that does satisfy diversity jurisdiction?

Held.

Yes, supplemental jurisdiction is granted when not all plaintiffs meet the amount in controversy requirement for diversity jurisdiction. The Eleventh Circuit is affirmed, and the First Circuit is reversed and remanded.

Dissent.

Justice Ruth Bader Ginsburg

Ginsburg argued for a narrower interpretation of 28 U.S.C. § 1367, which conformed with precedent. She argued that all claims in a complaint must satisfy all requirements of diversity jurisdiction as one civil action before supplemental jurisdiction can be granted to additional plaintiffs, barring plaintiffs who do not meet the requirements from joining through Rule 20 and Rule 23.

Discussion.

The Court determined that 28 U.S.C. § 1367 overruled precedent that required each individual plaintiff to satisfy any amount in controversy requirement under diversity jurisdiction. The Court reasoned that once a federal court had authority over one claim in a complaint, it has authority over the entire complaint as one civil action. Additionally, the Court found that nothing within the language of 28 U.S.C. § 1367 excluded supplemental jurisdiction for parties joining a suit under Rule 20 and Rule 23, unlike its explicit language against Rule 24 and Rule 19.