Exxon Mobil Corp. v. Allapattah Services, Inc.

About 10,000 dealers (plaintiffs) who purchased fuel from Exxon Mobil Corp. (Exxon) (defendant) filed a class-action suit against Exxon for alleged overcharges. The suit was filed in federal district court and invoked the court’s diversity jurisdiction. Some dealers’ claims satisfied the amount-in-controversy requirement for diversity jurisdiction, but others did not. The district court concluded that it had supplemental jurisdiction over noncompliant claims, and the jury held in the dealers’ favor. The Eleventh Circuit affirmed the district court’s exercise of supplemental jurisdiction. In a separate suit, a young girl (plaintiff) sued Star-Kist (defendant) in federal district court for injuries from slicing her finger on a Star-Kist tuna can. The girl’s family joined the suit, also seeking damages. The district court concluded that no party’s claim met the amount-in-controversy requirement for diversity jurisdiction and therefore granted summary judgment in Star-Kist’s favor. The First Circuit reversed in part, finding that the girl’s claim met the requirement. However, the First Circuit concluded that the district court did not have supplemental jurisdiction over the family members’ claims that did not meet the requirement. The United States Supreme Court consolidated the Exxon and Star-Kist cases, granting certiorari to resolve a circuit split regarding whether a district court may exercise supplemental jurisdiction over additional plaintiffs whose claims do not meet the amount-in-controversy requirement for diversity jurisdiction.