414 U.S. 291 (1973)
Petitioners, who owned property fronting on Lake Champlain in Orwell, Vermont, brought this diversity action in the District Court on behalf of themselves and approximately 200 other lakefront property owners and lessees.1 They sought damages from International Paper Co., a New York corporation, alleging that discharges from its pulp and paper-making plant in New York had flowed into Ticonderoga Creek and then into Lake Champlain, polluting the lake and damaging the value and utility of their properties.2 Jurisdiction was asserted under 28 U.S.C. § 1332(a)(1).3
The claim of each of the named plaintiffs was found to satisfy the $10,000 jurisdictional amount, but the District Court was convinced to a legal certainty that not every individual owner in the class had suffered pollution damages in excess of $10,000.4 Reading Snyder v. Harris as precluding maintenance of the action by any member of the class whose separate and distinct claim did not individually satisfy the jurisdictional amount and concluding that it would not be feasible to define a class of property owners each of whom had more than a $10,000 claim, the District Court refused to permit the suit to proceed as a class action.5
A divided Court of Appeals affirmed, principally on the authority of Snyder v. Harris.6 The Supreme Court granted certiorari.7
Whether each plaintiff in a Rule 23(b)(3) class action must satisfy the jurisdictional amount requirement individually?8
When two or more plaintiffs, having separate and distinct demands, unite for convenience and economy in a single suit, it is essential that the demand of each be of the requisite jurisdictional amount.9
Yes. The claim of each of the named plaintiffs was found to satisfy the $10,000 jurisdictional amount, but the District Court was convinced to a legal certainty that not every individual owner in the class had suffered pollution damages in excess of $10,000. Because the claims involve separate and distinct demands rather than a common and undivided interest, the rule requires dismissal of any plaintiff lacking the jurisdictional amount.10 The District Court correctly determined that redefining the class to include only qualifying members was not feasible, so the suit could not proceed as a class action.11
The District Court and Court of Appeals therefore properly refused to permit the suit to proceed as a class action.12
Related opinions on this issue
Justice Brennan dissented from the holding that every class member must individually satisfy the jurisdictional amount.13 He argued that once jurisdiction attaches through the named plaintiffs' claims, ancillary jurisdiction should extend to the claims of nonappearing class members in a Rule 23(b)(3) action.14 Brennan emphasized that the practical necessities of class actions align with prior exercises of ancillary jurisdiction over compulsory counterclaims and interventions as of right.15
He noted that the 1966 amendments to Rule 23 support this approach by focusing on the nature of the litigation.16 Denying ancillary jurisdiction would impose greater burdens on state and federal courts while leaving many claims unasserted due to their small individual value.17 Brennan distinguished Snyder v. Harris as addressing only whether the action as a whole could proceed on aggregated claims, not the treatment of individual class members once jurisdiction is established by the representatives.18
Whether the rationale of Snyder v. Harris requires dismissal of class members whose separate claims do not meet the jurisdictional amount?19
The rationale of Snyder v. Harris requires that in class actions involving separate and distinct claims, any plaintiff who does not meet the jurisdictional amount must be dismissed from the case, even though other plaintiffs assert jurisdictionally sufficient claims.20
Yes. Snyder v. Harris held that class actions with separate and distinct claims are subject to the rule that each plaintiff must present a claim exceeding the jurisdictional minimum, relying on Clark v. Paul Gray, Inc. to require dismissal of those without sufficient claims.21 Here the District Court was convinced to a legal certainty that not every individual owner in the class had suffered pollution damages in excess of $10,000, so the rationale of Snyder v. Harris mandated refusal of class action status rather than permitting some members to proceed while dismissing others.22 The lower courts therefore correctly applied Snyder v. Harris to bar the class action.23
The lower courts therefore correctly applied Snyder v. Harris to bar the class action.