Exxon Mobil Corp. v. Allapattah
United States Supreme Court
545 U.S. 546 (2005)
The United States Supreme Court consolidated two cases to resolve a split in the circuits regarding amount-in-controversy in diversity cases. The first case, Exxon Mobil Corp. v. Allapattah (2005), involved a class action of 10,000 Exxon dealers who brought suit against Exxon, alleging that the company was overcharging them for fuel. Some of the dealers’ damages did not rise to the amount required for diversity jurisdiction, but the district court and the United States Court of Appeals for the Eleventh Circuit allowed joinder, holding that the unnamed members of a class action suit were not all required to meet the amount-in-controversy requirement, so long as at least one plaintiff did. The second case involved a nine-year-old girl who sued Starkist based on the unusually serious injuries she endured when she cut herself on a tuna can. She attempted to join her parents as plaintiffs as well, but the district court held that none of the parties had damages to the level of the jurisdictional amount. On appeal, the Court of Appeals for the First Circuit found that while the parents’ damages were below the jurisdictional amount and therefore could not be properly joined, the girl’s damages were sufficient. The United States Supreme Court granted certiorari to resolve the split.
Rule of Law
Holding and Reasoning (Kennedy, J.)
Dissent (Ginsburg, J.)
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