545 U.S. 546, 558–59 (2005)
In 1991, about 10,000 Exxon dealers filed a class-action suit against the Exxon Corporation in the United States District Court for the Northern District of Florida.1 They alleged an intentional and systematic scheme by which they were overcharged for fuel purchased from Exxon.2 The plaintiffs invoked the District Court's diversity jurisdiction under 28 U.S.C. § 1332(a).3 Each dealer's claim was for slightly less than the $75,000 jurisdictional minimum.4 After a unanimous jury verdict in favor of the plaintiffs, the District Court certified the case for interlocutory review on the question of supplemental jurisdiction over class members who did not meet the jurisdictional minimum.5
In a separate action, a 9-year-old girl sued Star-Kist in a diversity action in the United States District Court for the District of Puerto Rico.6 She sought damages for unusually severe injuries she received when she sliced her finger on a tuna can.7 Her family joined in the suit seeking damages for emotional distress and medical expenses.8 The District Court granted summary judgment to Star-Kist, finding that none of the plaintiffs met the minimum amount-in-controversy requirement.9
The Court of Appeals for the Eleventh Circuit upheld the District Court's extension of supplemental jurisdiction to the class members who did not meet the amount requirement.10 The Court of Appeals for the First Circuit ruled that the injured girl, but not her family members, had made allegations of damages in the requisite amount.11 It further held that section 1367 authorizes supplemental jurisdiction only when the district court has original jurisdiction over the action.12 In a diversity case, original jurisdiction is lacking if one plaintiff fails to satisfy the amount-in-controversy requirement.13
The Supreme Court granted certiorari to resolve the conflict among the Courts of Appeals.14 The cases were consolidated before the Supreme Court.15
Whether a federal court in a diversity action may exercise supplemental jurisdiction over the claims of additional plaintiffs who do not meet the minimum amount in controversy requirement of 28 U.S.C. § 1332, provided that at least one named plaintiff satisfies that requirement?16
Section 1367(a) provides that in any civil action of which the district courts have original jurisdiction, the district courts shall have supplemental jurisdiction over all other claims that are so related to claims in the action within such original jurisdiction that they form part of the same case or controversy under Article III of the United States Constitution.17 Such supplemental jurisdiction shall include claims that involve the joinder or intervention of additional parties.18 Subsection (b) lists specific exceptions in diversity cases but does not include the joinder of additional plaintiffs whose claims do not independently satisfy the amount-in-controversy requirement.19
Yes. The text of § 1367(a) confers supplemental jurisdiction over all other claims forming part of the same case or controversy without carving out an exception for claims that do not independently satisfy the amount-in-controversy requirement.20
In the Exxon case, each named dealer's claim was slightly less than the jurisdictional minimum under § 1332, and the class members' claims likewise fell short.21
Yet all claims arose from the same nationwide scheme to overcharge for fuel.22
In the Star-Kist case, the injured girl's claim met the amount requirement while her family's did not.23
All claims stemmed from the same injury incident.24
Section 1367(b) does not list claims by permissively joined plaintiffs under Rule 20 or class members under Rule 23 as exceptions.25
This confirms that supplemental jurisdiction extends to these claims when at least one plaintiff meets the original jurisdiction requirements.26
Related opinions on this issue
Joined by Justices Stevens, O'connor, And Breyer
Justice Ginsburg dissented, joined by Justices Stevens, O'Connor, and Breyer.29 She argued that § 1367 does not authorize supplemental jurisdiction over claims of class members or additional plaintiffs who fail to meet the amount-in-controversy requirement.30 Her reading of the statute preserves the holdings in Clark and Zahn, requiring each plaintiff to independently satisfy the jurisdictional amount.31
She emphasized that the legislative history, particularly the House Report, confirms Congress intended only to overrule Finley and not to expand diversity jurisdiction by overruling Zahn.32 The broader reading would allow virtually any class action to proceed in federal court upon the claim of a single plaintiff meeting the threshold, a result Congress did not intend.33
Joined by Justice Breyer
Justice Stevens dissented, joined by Justice Breyer.34 He agreed with Justice Ginsburg's interpretation and stressed that the legislative history provides powerful confirmation that Congress did not intend to overrule Zahn.35 He criticized the majority for treating statutory interpretation as a pedantic exercise divorced from ascertaining congressional intent.36
The House Report explicitly states that the section is not intended to affect the jurisdictional requirements in diversity-only class actions as interpreted prior to Finley, citing Zahn.37 Stevens argued that the Court should be accountable to all reliable evidence of legislative intent rather than dismissing the clear history.38