Exxon Mobil Corp. v. Allapattah Services

Brief Fact Summary.

Exxon dealers obtained a jury verdict against Exxon Mobil Corp. in federal district court. The district court certified for review the question of whether supplemental jurisdiction under 28 USC 1367 was properly exercised over the claims of class members who did not meet the jurisdictional minimum amount in controversy for diversity jurisdiction. The Court of Appeals upheld the exercise of supplemental jurisdiction. The Supreme Court granted certiorari.

Synopsis of Rule of Law.

Where the other elements of jurisdiction are satisfied, and at least one named plaintiff in the action satisfies the diversity jurisdiction amount in controversy requirement, supplemental jurisdiction over the claims of other plaintiffs, whose claims are for less than the jurisdictional amount necessary for diversity jurisdiction, is authorized.

Facts.

Exxon dealers filed a class action lawsuit against Exxon Mobil Corp., based on diversity of citizenship. The dealers alleged that Exxon Mobil engaged in scheme to overcharge them for fuel purchases. After the Exxon dealers obtained a jury verdict, the district court certified the case for review of whether supplemental jurisdiction could be exercised over the claims of class members who did not meet the jurisdictional minimum amount in controversy for diversity jurisdiction. The Court of Appeals upheld the exercise of supplemental jurisdiction. The Supreme Court granted certiorari.

Issue.

Can a federal court exercise supplemental jurisdiction over additional plaintiffs whose claims do not satisfy the  amount in controversy requirement in a diversity action if those claims are part of the same case or controversy as those of the original plaintiff, whose claims do satisfy the diversity jurisdictional amount in controversy requirement?

Held.

Yes. A federal court can exercise supplemental jurisdiction over additional plaintiffs whose claims do not satisfy the  amount in controversy requirement if those claims are part of the same case or controversy as those of the original plaintiff, whose claims do satisfy the diversity jurisdictionalamount in controversy requirement?

Discussion.

28 U.S.C. 1367(a) authorizes the federal courts to exercise jurisdiction in a diversity case in which the claims of some plaintiffs satisfy the amount in controversy requirement although others do not, and section 1367(b) does not limit this authority. The court need not have original jurisdiction over every claim in the complaint.