In a class action lawsuit filed by Exxon dealers against Exxon Corp., in which the named plaintiff satisfied the amount in controversy requirement for diversity jurisdiction, the district court certified the case for interlocutory review, seeking a determination as to whether it had properly exercised jurisdiction over the claims of those class members whose claims did not satisfy the amount in controversy for federal diversity jurisdiction. The United States Court of Appeals for the Eleventh Circuit upheld jurisdiction; the Court of Appeals for the Fourth Circuit decided differently on this issue in a different case. The Supreme Court granted certiorari.
If a complaint contains multiple claims that are all part of the same case or controversy, and some of the claims are within the federal court’s jurisdiction based on diversity, the court has jurisdiction over other claims even if they are for less than the amount in controversy required for an independent basis for federal jurisdiction.
Exxon dealers filed a class action lawsuit against Exxon Corp. The named plaintiff in the class action lawsuit satisfied the amount in controversy requirement for diversity jurisdiction. The complaint alleged a scheme by Exxon Corp. to intentionally and systematically overcharge the dealers for fuel. After a plaintiffs’ verdict, the district court certified the case for interlocutory review, seeking a determination as to whether it had properly exercised jurisdiction over the claims of class members whose claims did not meet the minimum amount in controversy for federal diversity jurisdiction. The United States Court of Appeals for the Eleventh Circuit upheld jurisdiction. On the same issue in a different case, the Court of Appeals for the Fourth Circuit decided differently. The Supreme Court granted certiorari.
Where one named plaintiff in a class action lawsuit satisfies the amount in controversy requirement for diversity jurisdiction, does 28 U.S.C. 1367(a) confer supplemental jurisdiction over additional plaintiffs if their claims do not satisfy the jurisdictional amount but are part of the same case or controversy?
Yes. Where one named plaintiff in a class action lawsuit satisfies the amount in controversy requirement for diversity jurisdiction, 28 U.S.C. 1367(a) confers supplemental jurisdiction over additional plaintiffs whose claims do not satisfy the jurisdictional amount but are part of the same case or controversy.
Justice Ginsburg
Justice Ginsburg’s dissent argued that the Court opted for a broad reading of 28 USC 1367 that was disruptive of the Court’s earlier jurisprudence, and that a narrower construction was the better reading.
Justice Stevens
Justice Stevens added in dissent that the legislative history of 28 USC 1367 supported Justice Ginsburg’s interpretation of the law.
Interpreting 28 USC 1367(a), the Court concluded that nothing in the statute indicates an intention by Congress for there to be any meaningful substantive distinction between historically “ancillary” and “pendent” jurisdiction. If a complaint asserts multiple claims that are part of the same case or controversy, and the federal district court has jurisdiction over one claim, the court has before it “any civil action over of which the district courts have original jurisdiction.” Although a geographically non-diverse party can defeat every other claim in the lawsuit due to the geographic non-diversity, the same is not true for individual claims under the amount in controversy requirement.