Exxon Mobil Corp. v. Allapattah Services, Inc. case brief
Issue: Does personal jurisdiction need to be satisfied according to IS standards?
Posture: Two diff cases, affirmed for 11th circuit and reversed in first circuit. Exxon dealers filed suit in Florida District Court, plaintiffs won and appeals affirmed their use of jurisdiction. In Starkist, Puerto Rico District Ct ruled for defendants, appeals reversed but did not allow family members to go to court, SCOTUS reverses again.
Facts: Question of whether a fed ct in diversity action may exercise supplemental jurisdiction over additional plaintiffs whose claims don’t satisfy amount-in-controversy requirement while claims are part of same case as plaintiff’s case that does have a sufficient amount.
Exxon case – 10,000 Exxon dealers claim that Exxon schemed to overcharge the fuel that dealers purchased from Exxon. Jury verdict was for plaintiff, district court certified the case for interlocutory review asking if it properly exercised supplemental jurisdiction over plaintiffs who did not meet amount in controversy requirement.
Starkist – 9 year old girl sued them in diversity in U.S. District for District of Puerto Rico, and lost because District ct found that no one met the dollar amount needed. However, Ct of appeals reversed and let girl go through because her amount met minimum BUT said that family members cannot get through because do not meet requisite. SCOTUS reverses.
Decision: Said that as long as at least one plaintiff satisfies the amount in controversy requirement then there is no problem
Reasoning: **Notes from 792 - 796** said that Exxon mobile said that as long as there is at least one claim that satisfies the full jurisdictional amount in controversy requirement with no other jurisdictional defects, that satisfies original jurisdiction over claim. Further, once they look at jurisdiction question, they look at constitution and statute. Nothing in 1367 says anything about withholding supplemental jurisdiction over claims of plaintiffs certified as class action
Court says that as long as one claim has original jurisdiction (includes amount in controversy and diversity) and no other jurisdictional defects, then all claims can be brought in even without amount in controversy. (What about without diversity?) Once it determines if it has original jurisdiction, it goes to question of whether it has constitutional and statutory basis for the other claims.
Stevens Dissent: Looks at legislative history to support Ginsburg’s interpretation.
Ginsburg Dissent: Wants a narrower view of this statute. Wants claims to first meet 1332 instead of circumventing it through supplemental jurisdiction.
Summary judgment notes:
Judge Frank did not want summary judgment to be granted when there was the “slightest doubt as to the facts” in the 1940’s. Argued that summary judgment unjustly deprived litigants of their day in court. However, Judge Clark argued that summary judgment was necessary to avoid useless trials. Also attached Frank’s slightest doubt test because it is possible to doubt everything and his test does not help. However, Clark advised that trial by affidavit is not a substitute for a jury trial when a case is extremely complex, such as the Poller v. CBS, Inc, where credibility is so important.
Standard: only disputes that might affect the outcome of the suit under governing law will properly preclude the entry of summary judgment. Under this standard, a fact is material if the pleader of a claim or defense must prove it. **Must take reasonable inferences for the non-moving parties side**