545 U.S. 546
PROCEDURAL POSTURE: In a class action suit, the United States Court of Appeals for the Eleventh Circuit affirmed a district court's exercise of supplemental jurisdiction pursuant to 28 U.S.C.S. § 1367 with respect to class members who did not meet the amount in controversy. In a separate suit, the United States Court of Appeals for the First Circuit found that supplemental jurisdiction was lacking. The Supreme Court granted certiorari.
OVERVIEW: The circuits were split as to whether a federal court in a diversity action could exercise supplemental jurisdiction over additional plaintiffs whose claims did not satisfy the minimum amount in controversy.
-The Supreme Court consolidated two cases one from a court that agrees and another from a court that disagrees with supplemental jurisdiction.
-Case 1: Exxon: In 1991, 10,000.00 Exxon dealers filed a class-action lawsuit against Exxon Corporation. The dealers alleged Exxon intentionally and systematically schemed to overcharge for fuel purchased from Exxon. After winning the case, the court ordered an interlocutory review as to whether supplemental jurisdiction over all plaintiffs was proper. The court found that supplemental jurisdiction was proper.
-Case 2: In this case a 9 year old girl sued Star-Kist for damages. She alleged she suffered unusually severe injuries when slicing her finger on a can of tuna. Her family also joined the suit seeking damages for emotional distress and medical expenses. The court found the child but not the parents met the amount-in-controversy requirement thus supplemental jurisdiction would be improper, even though both claims arose from the same case and controversy.
The Supreme Court found that, where the other elements of jurisdiction were satisfied and at least one named plaintiff met the amount-in-controversy requirement, § 1367 authorized supplemental jurisdiction over claims of other plaintiffs in the same U.S. Const. art. III case or controversy, even if those claims were for less than the jurisdictional amount.
By enacting 28 U.S.C.S. § 1367, Congress overruled prior Supreme Court precedent that had required every plaintiff to separately satisfy the amount-in-controversy requirement. Although § 1367(b) precluded supplemental jurisdiction over claims of plaintiffs joined under Fed. R. Civ. P. 19 or intervenors under Fed. R. Civ. P. 24, nothing in the statute withheld jurisdiction over claims of plaintiffs permissively joined under Fed. R. Civ. P. 20 or certified as class members under Fed. R. Civ. P. 23. The Class Action Fairness Act, Pub. L. No. 109-2, 119 Stat. 4, did not affect the Court's interpretation of 28 U.S.C.S. § 1367.
OUTCOME: The judgment of the United States Court of Appeals for the Eleventh Circuit was affirmed. The judgment of the United States Court of Appeals for the First Circuit was reversed and remanded.
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