## Facts

- Charles T. Pinel, a Michigan resident, died owning a tract of land in Michigan; his will was admitted to probate in Michigan.
- The will devised the entire estate to some, but not all, of his eight children, omitting Herman Pinel, Sarah Slyfield, and Charles W. Pinel.
- Herman and Sarah filed suit in federal district court asserting that, under a Michigan statute, an omitted child takes an intestate share if omitted by mistake or accident.
- Herman claimed an undivided one-eighth interest in the estate.
- Sarah claimed an undivided two-eighths interest: her own one-eighth share plus an additional one-eighth share allegedly assigned to her by Charles W.
- The estate’s maximum value was alleged to be less than $12,000, making each plaintiff’s individual fractional interest worth less than the $3,000 jurisdictional minimum then required for diversity jurisdiction.

## Issues

1. In a diversity case with multiple plaintiffs asserting separate fractional shares in an estate, may the plaintiffs aggregate their claims to satisfy the federal amount-in-controversy requirement?
2. Do plaintiffs seeking separate shares in inherited property present a “common and undivided” interest permitting aggregation?

## Decision

- The Supreme Court affirmed dismissal for lack of subject-matter jurisdiction.
- The Court held the plaintiffs’ demands were separate and distinct, not a single common and undivided interest.
- Because neither plaintiff’s individual interest exceeded $3,000, aggregation was not permitted and federal jurisdiction was absent.

## Legal Principles

- When multiple plaintiffs with separate and distinct demands join in one action, each plaintiff must independently satisfy the jurisdictional amount.
- Aggregation is permitted only when plaintiffs unite to enforce a single title or right in which they have a common and undivided interest.
- In diversity cases, the amount in controversy must appear from the pleadings or proof to exceed the jurisdictional minimum for each separate claim unless a true common and undivided interest is shown.

## Conclusion

The Court held that heirs asserting separate fractional shares in an estate assert distinct demands, so their claims cannot be combined to meet the diversity amount-in-controversy threshold; each plaintiff must satisfy the jurisdictional amount independently unless the right enforced is common and undivided.


Pinel v. Pinel, 240 U.S. 594 (1916)