Exxon Corp. v. Allapattah Services, Inc. & Ortega v. Star-Kist Foods, Inc. (consolidated)
These consolidated cases illustrate a circuit split over the federal supplemental jurisdiction statute, 28 U.S.C. § 1367.
The plaintiffs in the Exxon case are a class of approximately 10,000 Exxon dealers who alleged that Exxon Corp. breached its dealer agreements by overcharging them for fuel purchases. After a trial, a jury returned a special verdict in favor of the dealers. After entering a final judgment for the dealers and denying their motion for the entry of a class-wide judgment, the district court certified a question for immediate appeal to the Eleventh Circuit Court of Appeals: whether it properly exercised "supplemental" jurisdiction over dealers whose claims did not meet the federal minimum requirement of $75,000. The court of appeals affirmed the district court, holding that the federal supplemental jurisdiction statute allows a district court in a class-action lawsuit to exercise supplemental jurisdiction over class members whose claims do not meet the jurisdictional minimum amount.
The Ortega case involves a minor who injured her finger on a can of Star-Kist tuna. The plaintiff and her family sued in federal court, asserting diversity jurisdiction. The district court dismissed the claims for lack of jurisdiction, holding that it was a legal certainty that none of the plaintiffs' claims was worth $75,000. The First Circuit Court of Appeals reversed as to the injured child, but upheld the district court's conclusion that none of the family members–whose claims largely consisted of emotional distress–satisfied the amount-in-controversy requirement.
Questions Presented:
Exxon Mobil Corp. v. Allapattah Servs., Inc.:
Whether the supplemental jurisdiction statute, 28 U.S.C. § 1367, authorizes federal courts with diversity jurisdiction over the individual claims of
named plaintiffs to exercise supplemental jurisdiction over the claims of absent class members that do not satisfy the minimum amount-in-controversy
requirement?
Ortega v. Star-Kist Foods, Inc.:
Whether, in a civil diversity action in which the claims of one plaintiff meet the amount-in-controversy threshold, 28 U.S.C. § 1367 authorizes the
district courts to exercise supplemental jurisdiction over the related claims of additional plaintiffs who do not satisfy the amount-in-controversy
requirement?
Decisions under Review:
Exxon Mobil Corp. v. Allapattah Servs., Inc.
Ortega v. Star-Kist Foods, Inc.
