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Pinel v. Pinel

240 U.S. 594, 36 S. Ct. 416, 60 L. Ed. 817 (1916)

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Pinel v. Pinel

United States Supreme Court

240 U.S. 594, 36 S. Ct. 416, 60 L. Ed. 817 (1916)

Facts

Charles T. Pinel (Mr. Pinel) had eight children. When Mr. Pinel died, his will did not include three of his children—Herman Pinel, Sarah Slyfield, and Charles W. Pinel. Herman and Sarah (plaintiffs) believed that they were unintentionally excluded from Mr. Pinel’s estate. Herman sought one-eighth of the estate, which he estimated was worth $1,500, and Sarah sought two-eighths of the estate—her share and her brother Charles’s share, because Charles had assigned his interest to her—which she estimated was worth $3,000. Herman and Sarah filed a lawsuit against their siblings who were included in the will (defendants) in federal district court. Herman and Sarah believed that the court had diversity jurisdiction over the case because their combined damages were $4,500, which exceeded the $3,000 amount-in-controversy requirement. The district court held that Herman and Sarah could not combine their damages to meet the amount-in-controversy requirement because they were each seeking a share of Mr. Pinel’s estate independently of the other’s claim rather than seeking to enforce a single right with a common claim. As neither Herman nor Sarah was seeking an amount that exceeded $3,000, the district court dismissed the case for lack of jurisdiction. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Pitney, J.)

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