## Facts

- Two diversity class actions were consolidated to resolve whether class members’ separate claims may be aggregated to satisfy 28 U.S.C. § 1332’s $10,000 amount-in-controversy requirement.
- In one action, a shareholder sued corporate directors alleging they received an excessive premium for selling control shares and that the excess should be shared among all shareholders under state law.
- The named shareholder alleged individual damages of $8,740 and sought to aggregate claims of about 4,000 shareholders to exceed $10,000.
- In the other action, a customer sued a utility alleging it unlawfully billed and collected a tax from customers outside certain city limits.
- The named customer alleged individual damages of $7.81 and sought to aggregate claims of about 18,000 customers to exceed $10,000.
- Lower courts split: one refused aggregation and dismissed for lack of jurisdiction; the other permitted aggregation and upheld jurisdiction.

## Issues

1. In a diversity class action under 28 U.S.C. § 1332, may separate and distinct claims of class members be aggregated to satisfy the statutory amount-in-controversy requirement?

## Decision

- The Supreme Court held, 7–2, that separate and distinct claims of class members may not be aggregated to meet § 1332’s amount-in-controversy requirement.
- The Court affirmed the judgment refusing aggregation and reversing the judgment permitting aggregation.
- The Court concluded the 1966 amendments to Federal Rule of Civil Procedure 23 did not alter the meaning of § 1332 or authorize aggregation.
- Because no named plaintiff alleged more than $10,000 and the class members’ claims were independent, federal diversity jurisdiction was absent.

## Legal Principles

- Separate and distinct claims of multiple plaintiffs generally cannot be aggregated to satisfy § 1332’s amount-in-controversy requirement.
- Aggregation is allowed when a single plaintiff asserts multiple claims against a single defendant, or when multiple plaintiffs seek to enforce a single title or right in which they share a common and undivided interest.
- Longstanding judicial construction of § 1332’s “matter in controversy” controls absent congressional change; reenactment of the same jurisdictional language is treated as acceptance of that construction.
- The Federal Rules of Civil Procedure, including Rule 23, cannot expand statutory subject-matter jurisdiction under the Rules Enabling Act.

## Conclusion

The Court ruled that class-action status does not permit aggregating class members’ separate claims to reach the diversity jurisdictional minimum, and that amendments to Rule 23 cannot expand the jurisdiction Congress set in § 1332.


Snyder v. Harris, 394 U.S. 332 (1969)