Exxon Mobil Corp. v. Allapattah Services, Inc.

545 U.S. 546 (2005)


In 1991, about 10,000 Exxon dealers (P) filed a class action suit against the Exxon Corporation (D) in the United States District Court. Ps alleged an intentional and systematic scheme by D under which they were overcharged for fuel purchased from D. Ps invoked the District Court's §1332(a) diversity jurisdiction. After a unanimous jury verdict in favor of Ps, the District Court certified the case for interlocutory review, asking whether it had properly exercised §1367 supplemental jurisdiction over the claims of class members who did not meet the jurisdictional minimum amount in controversy. The Eleventh Circuit affirmed. This decision accords with the views of the Courts of Appeals for the Fourth, Sixth, and Seventh Circuits. The Courts of Appeals for the Fifth and Ninth Circuits, adopting a similar analysis of the statute, held that in a diversity class action the unnamed class members need not meet the amount in controversy requirement, provided the named class members do. These decisions are unclear on whether all the named plaintiffs must satisfy this requirement. The First Circuit took a different position on the meaning of §1367(a). In its case, consolidated herein, a 9-year-old girl sued Star-Kist in a diversity action seeking damages for unusually severe injuries she received when she sliced her finger on a tuna can. Her family joined in the suit, seeking damages for emotional distress and certain medical expenses. The District Court granted summary judgment to Star-Kist, finding that none of the plaintiffs met the minimum amount in controversy requirement. The Court of Appeals for the First Circuit, however, ruled that the injured girl, but not her family members, had made allegations of damages in the requisite amount. The court held that § 1367 authorizes supplemental jurisdiction only when the district court has original jurisdiction over the action and that in a diversity case original jurisdiction is lacking if one plaintiff fails to satisfy the amount in controversy requirement. This view is shared by the Courts of Appeal for the Third, Eighth, and Tenth Circuits, and the latter two Courts of Appeals have expressly applied this rule to class actions. The Supreme Court consolidated and granted certiorari.