Facts
- Approximately 10,000 Exxon dealers filed a federal diversity class action alleging Exxon overcharged them for fuel.
- The district court entered judgment for the dealers and certified an interlocutory appeal on whether it could hear class members’ claims that did not meet the amount-in-controversy minimum.
- The Eleventh Circuit held supplemental jurisdiction existed under 28 U.S.C. § 1367 over class members whose claims fell below the jurisdictional amount.
- Separately, a minor and her family sued Star-Kist in federal court on diversity after the minor cut her finger on a tuna can.
- The district court granted summary judgment, concluding no plaintiff met the amount-in-controversy requirement.
- The First Circuit held the minor satisfied the jurisdictional amount but her family did not, and it rejected supplemental jurisdiction over the family members’ below-threshold claims.
- The Supreme Court granted certiorari and consolidated the cases due to a circuit split on the meaning of § 1367 in diversity actions.
Issues
- Whether 28 U.S.C. § 1367 authorizes supplemental jurisdiction in a diversity action over additional plaintiffs’ related claims that do not meet § 1332(a)’s amount-in-controversy requirement, when at least one plaintiff’s claim does and complete diversity exists.
- Whether § 1367(b) bars supplemental jurisdiction over such below-threshold claims by additional plaintiffs in multi-plaintiff or class actions.
Decision
- The Court held, 5–4, that § 1367 authorizes supplemental jurisdiction over additional plaintiffs’ related claims that fall below the amount-in-controversy requirement when complete diversity exists and at least one plaintiff satisfies § 1332(a).
- The Court affirmed the Eleventh Circuit in the Exxon dealers case.
- The Court reversed the First Circuit in the Ortega case and remanded.
- The Court read § 1367(a) as a broad grant covering all related claims within the same Article III case or controversy, subject only to the specific limits stated in § 1367(b).
- The Court concluded § 1367 displaced prior rules requiring each plaintiff independently to meet the amount-in-controversy minimum, so long as the statutory exceptions in § 1367(b) do not apply.
Legal Principles
- If a district court has original jurisdiction over at least one claim in a civil action, § 1367(a) permits supplemental jurisdiction over other claims that are part of the same Article III case or controversy.
- In diversity cases, supplemental jurisdiction under § 1367 does not cure lack of complete diversity; if complete diversity is absent, original jurisdiction is lacking.
- In a diversity action with complete diversity, the amount-in-controversy requirement is satisfied if at least one plaintiff meets § 1332(a); related claims by other plaintiffs may proceed under § 1367(a) even if they seek less than the jurisdictional minimum.
- Section 1367(b) limits supplemental jurisdiction only in the specific categories it enumerates; courts should not add extra, unwritten restrictions on supplemental jurisdiction in diversity cases.
- The decision allows federal jurisdiction over related, below-threshold claims in multi-plaintiff and class actions when anchored by at least one claim meeting the jurisdictional amount.
Conclusion
The Court interpreted § 1367 to permit supplemental jurisdiction in diversity cases over additional plaintiffs’ related claims that fall below the amount-in-controversy minimum, provided complete diversity exists and at least one plaintiff’s claim satisfies § 1332(a), and the claims are not barred by § 1367(b)’s enumerated exceptions.