Exxon Mobil Corp. v. Allapattah
United States Supreme Court
545 U.S. 546 (2005)
The Court consolidated two cases raising the same jurisdictional question. In one, 10,000 Exxon dealers (plaintiffs) sued Exxon (defendant) for overcharging them, and lower courts allowed joinder even though some dealers' damages fell below the jurisdictional amount, so long as one plaintiff met it. In the other, a child injured by a tuna can sued Starkist and tried to join her parents as plaintiffs; the parents' damages did not meet the jurisdictional amount, but the child's did, and the First Circuit allowed the child's claim while barring the parents'. The Supreme Court granted certiorari to resolve the resulting circuit split over supplemental jurisdiction under 28 U.S.C. section 1367.
Whether, when other elements of diversity jurisdiction are present and at least one named plaintiff satisfies the amount-in-controversy requirement, a court may exercise jurisdiction over other properly joined plaintiffs whose damages do not reach the jurisdictional amount.