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EXXON MOBIL CORP. V. ALLAPATTAH SERVICES, INC. (04-70)
Web-accessible at:
http://supct.law.cornell.edu/supct/html/04-70.ZS.html
Argued March 1, 2005 -- Decided June 23, 2005*
Opinion author: Kennedy
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In No. 04-70, Exxon dealers filed a
class action against Exxon Corporation, invoking the Federal
District Court's 28 U.S.C. sect.
1332(a) diversity jurisdiction. After the dealers won a
jury verdict, the court certified the case for interlocutory
review on the question whether it had properly exercised
sect.1367 supplemental jurisdiction over the claims of class
members who had not met sect.1332(a)'s minimum
amount-in-controversy requirement. The Eleventh Circuit upheld
this extension of supplemental jurisdiction. In No.
04-79, a girl and her family sought damages from Star-Kist
Foods, Inc., in a diversity action. The District Court granted
Star-Kist summary judgment, finding that none of the plaintiffs
had met the amount-in-controversy requirement.The First
Circuit ruled that the girl, but not her family, had alleged
the requisite amount, and then held that supplemental
jurisdiction over the family's claims was improper because
original jurisdiction is lacking in a diversity case if one
plaintiff fails to satisfy the amount-in-controversy
requirement.
Held: Where the other elements of
jurisdiction are present and at least one named plaintiff in
the action satisfies sect.1332(a)'s amount-in-controversy
requirement, sect.1367 authorizes supplemental jurisdiction
over the claims of other plaintiffs in the same Article III
case or controversy, even if those claims are for less than the
requisite amount. Pp. 4-25.
(a) Although
district courts may not exercise jurisdiction absent a
statutory basis, once a court has original jurisdiction over
some claims in an action, it may exercise supplemental
jurisdiction over additional claims arising from the same case
or controversy. See Mine Workers v. Gibbs, 383 U.S. 715. This
expansive interpretation does not apply to sect.1332's
complete diversity requirement, for incomplete diversity
destroys original jurisdiction with respect to all claims,
leaving nothing to which supplemental claims can adhere. But
other statutory prerequisites, including the federal-question
and amount-in-controversy requirements, can be analyzed claim
by claim. Before sect.1367 was enacted, every plaintiff had
to separately satisfy the amount-in-controversy requirement,
Clark v. Paul Gray, Inc., 306 U.S. 583;
Zahn v. International Paper Co., 414 U.S. 291, and the
grant of original jurisdiction over claims involving particular
parties did not itself confer supplemental jurisdiction over
additional claims involving other parties, Finley v.
United States, 490 U.S. 545, 556.
Pp. 4-9.
(b) All
parties here agree that sect.1367 overturned Finley,
but there is no warrant for assuming that is all it did. To
determine sect.1367's scope requires examination of the
statute's text in light of context, structure, and related
statutory provisions. Section 1367(a) is a broad grant of
supplemental jurisdiction over other claims within the same
case or controversy, as long as the action is one in which
district courts would have original jurisdiction. Its last
sentence makes clear that this grant extends to claims
involving joinder or intervention of additional parties. The
question here is whether a diversity case in which the claims
of some, but not all, plaintiffs satisfy the
amount-in-controversy requirement qualifies as a "civil
action of which the district courts have original
jurisdiction," sect.1367(a). Pp. 9-11.
(c) The
answer must be yes. When a well-pleaded complaint has at least
one claim satisfying the amount-in-controversy requirement, and
there are no other relevant jurisdictional defects, the
district court, beyond all question, has original jurisdiction
over that claim. A court with original jurisdiction over a
single claim in the complaint has original jurisdiction over a
"civil action" under sect.1367(a), even if that
action comprises fewer claims than were included in the
complaint. Once a court has original jurisdiction over the
action, it can then decide whether it has a constitutional and
statutory basis for exercising supplemental jurisdiction over
other claims in the action. Section 1367(b), which contains
exceptions to sect.1367(a)'s broad rule, does not
withdraw supplemental jurisdiction over the claims of the
additional parties here. In fact, its exceptions support this
Court's conclusion. Pp. 11-13.
(d) The
Court cannot accept the alternative view, or its supporting
theories, that a district court lacks original jurisdiction
over a civil action unless it has original jurisdiction over
every claim in the complaint. The "indivisibility
theory"--that all claims must stand or fall as a
single, indivisible action--is inconsistent with the whole
notion of supplemental jurisdiction and is belied by this
Court's practice of allowing federal courts to cure
jurisdictional defects by dismissing the offending parties
instead of the entire action. And the statute's broad and
general language does not permit the theory to apply in
diversity cases when it does not apply in federal-question
cases.The "contamination theory"--that
inclusion of a claim or party falling outside the district
court's original jurisdiction contaminates every other
claim in the complaint--makes sense with respect to the
complete diversity requirement because a nondiverse
party's presence eliminates the justification for a
federal forum.But it makes little sense with regard to the
amount-in-controversy requirement, which is meant to ensure
that a dispute is sufficiently important to warrant
federal-court attention. It is fallacious to suppose, simply
from the proposition that sect.1332 imposes both requirements,
that the contamination theory germane to the former also
applies to the latter.This Court has already considered and
rejected a virtually identical argument in the closely
analogous removal-jurisdiction context. See Chicago v.
International College of Surgeons, 522 U.S. 156.
Pp. 13-19.
(e) In light
of the statute's text and structure, sect.1367's
only plausible reading is that a court has original
jurisdiction over a civil action comprising the claims for
which there is no jurisdictional defect. Though a single
nondiverse party can contaminate every other claim in a
lawsuit, contamination does not occur with respect to
jurisdictional defects going only to the substantive importance
of individual claims. Thus, sect.136
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