EXXON CORP v. ALLAPATTAH SERVICES

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Case Basics
Docket No. 
04-70
Petitioner 
Exxon Mobil Corporation
Respondent 
Allapattah Services, Inc., et al.
Consolidation 
Maria del Rosario Ortega, et al. v. Star-Kist Foods, Inc., No. 04-79
Advocates
(argued the cause for Petitioner in 04-70)
(argued the cause for Respondents in 04-70)
(argued the cause for Respondent in 04-79)
(argued the cause for Petitioner in 04-79)
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Facts of the Case 

In 1991 about 10,000 Exxon dealers sued Exxon Corporation in federal court, alleging that the corporation had engaged in an extensive scheme to overcharge them for fuel. A jury found in favor of the plaintiffs, but the District Court judge certified the case for review on the question of supplemental jurisdiction. Some of the multiple plaintiffs in the case had claims that did not meet the minimum amount necessary to qualify for federal diversity jurisdiction (currently $75,000). In 1990 Congress had enacted 28 U.S.C. Section 1367, overturning Finley v. United States, which had narrowly interpreted federal courts' power to confer supplementary jurisdiction on related claims. The question for the District Court was whether Section 1367 also overturned Zahn v. International Paper Co., which ruled that each plaintiff had to separately meet the minimum amount-in-controversy requirement. The District Court accepted the plaintiffs' argument that Section 1367 gave federal courts power to exercise supplemental jurisdiction over plaintiffs with related claims, even if some plaintiffs' claims did not meet the required amount. On appeal, the Eleventh Circuit Court of Appeals upheld the District Court's ruling on supplemental jurisdiction. However, this ruling conflicted with the ruling of another Circuit, which had taken the opposite view of Section 1367's scope (see Ortega v. Star-Kist Foods, No. 04-79). The Supreme Court granted certiorari and consolidated the cases for argument.

Question 

In a civil action where one plaintiff's claim satisfies the minimum amount-in- controversy requirement for federal diversity jurisdiction, and another plaintiff's related claim does not, does 28 U.S.C. Section 1367 allow federal courts to exercise supplemental jurisdiction over the claim that is less than the required amount?

Conclusion 
Decision: 5 votes for Allapattah Services, 4 vote(s) against
Legal provision: 28 U.S.C. 1367

Yes. In a 5-4 decision, the Court ruled that as long one plaintiff meets the amount-in-controversy requirement for federal jurisdiction, Section 1367 authorizes federal courts to exercise supplemental jurisdiction over related claims even if they do not meet the requirement. The majority opinion by Justice Anthony Kennedy held that courts only need to determine whether they have original jurisdiction over one of the claims in a case. If they do, courts can then decide to extend supplemental jurisdiction to the other related claims. The Justices ruled that to require each claim in a civil action to meet the requirement would be "inconsistent with the whole notion of supplemental jurisdiction." The Court based its ruling on the "unambiguous[]" text of the statute, saying "the authoritative statement is the statutory text, not the legislative history or any other extrinsic material." Justice Stevens, joined by Justice Breyer, wrote a dissenting opinion arguing that the Court should have consulted the legislative history of Section 1367. Justice Ginsburg, joined by Justices Stevens, O'Connor, and Breyer, wrote a dissent arguing for a narrower interpretation of Section 1367 that would not overturn Zahn.

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EXXON CORP v. ALLAPATTAH SERVICES. The Oyez Project at IIT Chicago-Kent College of Law. 04 April 2014. <http://www.oyez.org/cases/2000-2009/2004/2004_04_70>.
EXXON CORP v. ALLAPATTAH SERVICES, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2000-2009/2004/2004_04_70 (last visited April 4, 2014).
"EXXON CORP v. ALLAPATTAH SERVICES," The Oyez Project at IIT Chicago-Kent College of Law, accessed April 4, 2014, http://www.oyez.org/cases/2000-2009/2004/2004_04_70.