Exxon Mobil Corp. v. Allapattah Services, Inc.
Citation
545 U.S. 546 (U.S. Supreme Court, 2005)
Facts
In a class action against Exxon Mobil, the named plaintiff and some class members satisfied the amount-in-controversy requirement for diversity jurisdiction, but other unnamed class members had claims below the $75,000 threshold. The question was whether the court could exercise jurisdiction over the claims of class members who did not independently meet the amount-in-controversy requirement.
Issue
Whether 28 U.S.C. § 1367 supplemental jurisdiction permits a federal court to exercise jurisdiction over claims of class members who do not independently satisfy the amount-in-controversy requirement when at least one named plaintiff does.
Holding
The Supreme Court held that § 1367 grants supplemental jurisdiction over all claims in the action as long as the district court has original jurisdiction over the case, meaning at least one named plaintiff satisfies the requirements; the remaining class members need not independently do so.
Rule
§ 1367 supplemental jurisdiction is available over all claims in a civil action if the court has original jurisdiction over the action; minority-claim plaintiffs need not independently satisfy amount-in-controversy once the case is properly in federal court.