Compton v. Alpha Kappa Alpha Sorority, Inc.

Sandra Compton and Lessie Cofield (plaintiffs) were long-standing members of Alpha Kappa Alpha Sorority, Inc. (AKA) (defendant). AKA was an organization with a rich history dedicated to counteracting the effects of discrimination and patriarchy against African-American women. Compton and Cofield had hoped their respective daughters (the daughters) would join AKA when they attended Howard University (Howard) (defendant). However, due to a series of unanticipated events, the daughters were not able to join AKA. Compton and Cofield sued AKA and Howard for breach of contract, tortious interference with contractual relations, and negligence, alleging that their daughters were wrongfully denied entry to AKA at Howard. Compton and Cofield contended that the amount in controversy in their lawsuits, including medical bills, emotional harm, mental anguish, loss of prospective economic advantages, and punitive damages, exceeded $75,000. AKA and Howard argued that Compton and Cofield’s claims must be dismissed for lack of subject matter jurisdiction because neither Compton nor Cofield could recover more than $75,000 in damages for the harm they alleged. Compton and Cofield also alleged that—following the filing of the suit—AKA withdrew their membership privileges. As a result, Compton and Cofield filed additional claims against AKA for ultra vires acts and intentional infliction of emotional harm (the remaining claims).