Exxon Mobil Corp. v. Allapattah Services, Inc.

Facts

In 1991, about 10,000 Exxon dealers filed a class action against the Exxon Corporation in federal court in the Northern District of Florida. They alleged an intentional and systematic scheme under which Exxon overcharged them for fuel. They relied on diversity jurisdiction under § 1332(a), which covers suits between citizens of different States. After a unanimous jury verdict for the plaintiffs, the District Court certified the case for interlocutory review (appeal before final judgment). It asked whether it had properly exercised supplemental jurisdiction under § 1367 over class members who did not meet the minimum amount in controversy. The second case came from Puerto Rico. A 9-year-old girl sued Star-Kist in a diversity action in federal court in the District of Puerto Rico. She sought damages for unusually severe injuries after she sliced her finger on a tuna can. Her family joined the suit and sought damages for emotional distress and certain medical expenses. The District Court granted summary judgment to Star-Kist because it found that none of the plaintiffs met the minimum amount in controversy. The First Circuit ruled that the girl, but not her family members, had alleged damages in the requisite amount.

Issues

1. May a federal court in a diversity action exercise supplemental jurisdiction under 28 U.S.C. § 1367 over additional plaintiffs whose claims fall below the amount-in-controversy minimum, when their claims are part of the same case or controversy as the claims of a plaintiff who meets it?
2. Does a diversity case in which some plaintiffs' claims meet the amount-in-controversy requirement and others' do not present a “civil action of which the district courts have original jurisdiction” under § 1367(a)?

Holding

Where the other elements of jurisdiction are present and at least one named plaintiff satisfies the amount-in-controversy requirement, § 1367 authorizes supplemental jurisdiction over the claims of other plaintiffs in the same Article III case or controversy, even if their claims are for less than the jurisdictional amount. By its plain text, § 1367 overruled Clark and Zahn.