Exxon Mobil Corp. v. Allapattah Services, Inc., 545 U.S. 546 (2005)
Primary Holding
A federal court in a diversity action may exercise supplemental jurisdiction over additional plaintiffs whose claims do not meet the minimum amount-in-controversy requirement, as long as at least one named plaintiff satisfies that requirement and the claims are part of the same case or controversy.
In the case of Exxon Mobil Corp. v. Allapattah Services, Inc., a group of Exxon dealers sued the company for being overcharged for fuel. The Supreme Court decided that if at least one person in a lawsuit meets the minimum amount needed to bring the case to federal court, then others in the same lawsuit can join in even if their claims are for smaller amounts. This ruling helps consumers by allowing more people to participate in legal actions against big companies, ensuring that even smaller claims can be heard as part of a larger case. This case is relevant if you believe you have a claim against a company but your individual claim is below the required amount for a federal lawsuit.
AI-generated plain-language summary to help you understand this case
Circuit courts disagreed over the application of the federal supplemental jurisdiction statute, found at 28 U.S.C. Section 1367. The group of cases that were consolidated for review included an action brought by 10,000 gas dealers who were suing Exxon Mobil Corp. for overcharging them for fuel purchases. The lower court ruled for the dealers, and the appellate court agreed with the rule stated in the Primary Holding above. In a personal injury case involving a nine-year-old girl who hurt her finger on a can of Star-Kist tuna, meanwhile, a different federal district court dismissed the action on the grounds that it did not have jurisdiction under a theory of diversity. It stated that this was based on the failure of some claims to meet the minimum amount in controversy requirement. On appeal, only the girl's individual claim was allowed to proceed.
Whether a federal court in a diversity action may exercise supplemental jurisdiction over additional plaintiffs whose claims do not satisfy the minimum amount-in-controversy requirement, provided the claims are part of the same case or controversy as the claims of plaintiffs who do allege a sufficient amount in controversy.
The judgment is affirmed.
This case overruled a precedent in the same area and expanded in the scope of diversity jurisdiction in an area of litigation that has become increasingly prevalent.
- Court
- Supreme Court
- Decision Date
- March 1, 2005
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280 (2005)
Consumer LostThe Rooker-Feldman doctrine is limited to cases where state-court losers seek to challenge state court judgments in federal court, and it does not extend to other situations that would override preclusion law or allow federal courts to dismiss cases in deference to state court actions.
Lincoln Property Co. v. Roch, 546 U.S. 81 (2005)
Consumer LostDefendants may remove a civil action from state court to federal court based on diversity of citizenship if there is complete diversity between all named plaintiffs and all named defendants, and no defendant is a citizen of the forum State; it is not the responsibility of the named defendants to prove the nonexistence of a potential defendant whose presence would destroy diversity.
Martin v. Franklin Capital Corp., 546 U.S. 132 (2005)
Consumer LostA federal court has discretion to award attorney's fees when remanding a case to state court under 28 U.S.C. § 1447(c), and such an award is appropriate only if the removing party lacked objectively reasonable grounds for believing that the removal was legally proper.
Exxon Shipping Co. v. Baker, 554 U.S. 471 (2008)
Consumer LostA shipowner may be liable for punitive damages in maritime law, but such damages should not exceed the amount of compensatory damages awarded.