Exxon Mobil Corp. v. Allapattah Services, Inc

In Exxon Mobil Corp. v. Allapattah Services, Inc., 545 U.S. 546, 125 S.Ct. 2611, 162 L.Ed.2d 502 (2005), the Supreme Court considered whether the supplemental jurisdiction statute, 28 U.S.C. 1367, enabled federal courts to exert jurisdiction over plaintiff class members who did not individually meet 1332(a)'s amount in controversy requirement. The Supreme Court answered in the affirmative, holding that where the other elements of jurisdiction are present and at least one named plaintiff in the action satisfies the amount-in-controversy requirement, 1367 does authorize supplemental jurisdiction over the claims of other plaintiffs in the same Article III case or controversy, even if those claims are for less than the jurisdictional amount specified in 1332(a). Id. at 549, 125 S.Ct. at 2615. This means that "when the well-pleaded complaint contains at least one claim that satisfies the amount-in-controversy requirement, and there are no other relevant jurisdictional defects, the district court, beyond all question, has original jurisdiction over that claim." Id. at 559, 125 S.Ct. at 2620. In Exxon Mobil Corp. v. Allapattah Servs., Inc., 545 U.S. 546 , 572, 125 S. Ct. 2611, 2616, 162 L. Ed. 2d 502 (2005), the Court was faced with the question of whether a district court had jurisdiction over a case where some plaintiffs claims satisfied the amount in controversy requirement, but others did not. The Court held: When the well-pleaded complaint contains at least one claim that satisfies the amount-incontroversy requirement, and there are no other relevant jurisdictional defects, the district court, beyond all question, has original jurisdiction over that claim. The presence of other claims in the complaint, over which the district court may lack original jurisdiction, is of no moment. If the court has original jurisdiction over a single claim in the complaint, it has original jurisdiction over a civil action within the meaning of 28 U.S.C. 1367(a), even if the civil action over which it has jurisdiction comprises fewer claims than were included in the complaint. Once the court determines it has original jurisdiction over the civil action, it can turn to the question whether it has a constitutional and statutory basis for exercising supplemental jurisdiction over the other claims in the action. Id. at 559, 125 S. Ct. at 2620-21.