Snyder v. Harris (Gas Service Co. v. Coburn)

Brief Fact Summary.

In separate cases, Snyder (Plaintiff) and Coburn (Plaintiff), sought to aggregate the claims of all of the parties represented in their class action lawsuits in order to meet the amount in controversy threshold for federal diversity jurisdiction.

Synopsis of Rule of Law.

Separate and distinct claims of various claimants in a class action may not be aggregated in order to meet the amount in controversy requirement for federal diversity jurisdiction.

Facts.

Snyder (Plaintiff) and Coburn (Plaintiff) each brought class action lawsuits in which no one individual’s claim exceeded the $10,000 amount in controversy requirement for federal diversity jurisdiction. Each Plaintiff attempted to aggregate the claims of the entire class in order to meet the requirement and establish jurisdiction. The Eighth Circuit denied Snyder’s effort while the Tenth Circuit allowed Coburn’s. The Supreme Court granted certiorari and consolidated the cases.

Issue.

May separate claims made within a single class action lawsuit be aggregated in order to meet the amount in controversy required for federal diversity jurisdiction?

Held.

(Black, J.) No. Separate and distinct claims of various claimants in a class action may not be aggregated in order to meet the amount in controversy requirement for federal diversity jurisdiction. Aggregation is allowed when one plaintiff combines two or more claims against the same defendant or when two or more plaintiffs seek to enforce a single title or right in which they have a common and undivided interest. Although a Federal Rule of Civil Procedure was modified to change the manner of classifying class action lawsuits, this modification does not change the determination of which claims may be aggregated. The Eighth Circuit decision is affirmed and the Tenth Circuit decision is reversed.

Dissent.

(Fortas, J.) The modification to the Federal Rule of Civil Procedure that addressed class actions does allow the aggregation of claims in all class action law suits.

Discussion.

A single plaintiff with multiple claims against the same defendant may invoke federal diversity jurisdiction if the claims together exceed the amount in controversy required even where no one claim reaches that threshold. Additionally, if one plaintiff’s claim exceeds the amount in controversy required, diversity jurisdiction will not be destroyed by joining additional plaintiffs with claims below that amount so long as all of the claims are based on the same operative facts and would ordinarily be litigated together. This is an example of ancillary jurisdiction.