Exxon Mobil Corp. v. Allapattah Services, Inc.

545 U.S. 546 · 2005

Facts

In 1991, approximately 10,000 Exxon dealers initiated a class-action lawsuit against Exxon Corporation, alleging a systematic scheme of overcharging for fuel. Separately, a 9-year-old girl sued Star-Kist for severe injuries sustained from a tuna can. Her family joined this suit, seeking damages for emotional distress and medical expenses related to the incident.

Issue

Whether a federal court in a diversity action may exercise supplemental jurisdiction over additional plaintiffs whose claims do not satisfy the minimum amount-in-controversy requirement, provided those claims are part of the same case or controversy as the claims of plaintiffs who do allege a sufficient amount in controversy, under 28 U.S.C. § 1367.

Holding

Yes, where other jurisdictional elements 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 those claims are for less than the jurisdictional amount. The judgment of the Eleventh Circuit was affirmed, and the judgment of the First Circuit was reversed.

Rule

Section 1367(a) grants broad supplemental jurisdiction over all claims forming part of the same Article III case or controversy, including those involving additional parties, as long as the district court has original jurisdiction over the "civil action." A "civil action of which the district courts have original jurisdiction" exists when at least one claim in the well-pleaded complaint satisfies the amount-in-controversy requirement, even if other claims do not. Section 1367(b) lists specific exceptions for diversity cases, but it does not withdraw supplemental jurisdiction over claims by plaintiffs permissively joined under Rule 20 or certified as class-action members under Rule 23. This interpretation overrules prior precedents like Clark and Zahn.

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