Snyder v. Harris

Background

A shareholder brought a federal diversity suit claiming about $8,740 for herself and asking to represent roughly 4,000 other shareholders; a Kansas customer sued a gas company for $7.81 and sought to represent about 18,000 similarly situated customers. Both cases were styled as class actions and raised the same question: may a federal court add together separate claims of many class members to meet the $10,000 amount required for diversity jurisdiction under 28 U.S.C. § 1332?

Reasoning

The Court focused on the longstanding rule that separate and distinct claims by different plaintiffs cannot be aggregated to reach the jurisdictional amount, except when one plaintiff has multiple claims or when plaintiffs share a single undivided interest. The majority said that this rule rests on Congress’s statute-making and the phrase “matter in controversy,” not on procedural categories of old Rule 23. The 1966 amendment to Rule 23 that changed how class actions are run did not, the Court held, change the statutory jurisdictional test, and rules cannot expand federal courts’ statutory jurisdiction. The result: the Court rejected aggregation in these class actions and resolved conflicting appeals from different circuits.

Real world impact

As a practical result, many high‑volume, low‑value claims cannot be bundled in federal court simply to meet the $10,000 diversity floor; some disputes must proceed in state court or be pursued under other federal jurisdictional bases. The opinion notes existing state-court suits and that Congress, not the courts, would have to change the jurisdictional rule.

Dissents or concurrances

A dissent argued the 1966 Rule 23 amendment intended to make class procedures count the combined value of the class and that refusing to allow aggregation defeats the purpose of the new class-action rule and limits access to federal courts for many class claims.