Exxon Mobil Corp. v. Allapattah Services, Inc.
The Supreme Court ruled that federal courts can hear the claims of additional plaintiffs in a diversity lawsuit even if those claims fall below the money threshold normally required, so long as at least one plaintiff in the case meets that threshold and all the claims arise from the same dispute.
The decision resolved a long-running split among federal appeals courts over how broadly a 1990 law on 'supplemental jurisdiction' should be read, and it opened federal courthouse doors to many class-action and multi-plaintiff diversity suits that lower courts had previously turned away.
“Under § 1367, the court has original jurisdiction over the civil action comprising the claims for which there is no jurisdictional defect.”
The Court's core holding on how far supplemental jurisdiction extends under the statute.
How it got here: The Eleventh Circuit upheld extended jurisdiction over the Exxon dealers' class, while the First Circuit rejected it for the Star-Kist family; the Supreme Court took both cases to resolve the conflict.
The Case in Depth
What happened
Thousands of Exxon gas station dealers sued Exxon in Florida federal court, claiming they were systematically overcharged for fuel, and won a jury verdict. Separately, a young girl badly cut her finger on a tuna can and, with her family, sued Star-Kist in Puerto Rico federal court for her injuries and the family's related losses. In both cases, only some plaintiffs' claims were large enough to meet the usual dollar threshold for federal diversity cases.
The question before the Court
If one plaintiff in a diversity lawsuit had a big enough claim, could a federal court still hear the smaller claims of other plaintiffs joined in the same suit?
The Court's answer
Yes — the Court ruled that once a federal diversity lawsuit has at least one plaintiff whose claim is large enough to meet the $75,000 threshold, the court has "original jurisdiction" over the whole action, and a 1990 law called Section 1367 lets it also hear the related claims of other plaintiffs even though those claims are smaller. The Court reasoned that Congress wrote Section 1367 broadly and did not carve out an exception for plaintiffs who fall short on the dollar amount alone, only for certain plaintiffs added under specific procedural rules.
Because Section 1367's exceptions did not mention the situations in these two cases, the Court concluded Congress meant to allow the smaller claims to ride along with the qualifying claim. That reading meant the Exxon dealers' class action could proceed as certified, while the Star-Kist family's claims should not have been dismissed just because their claims were too small on their own.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Businesses and consumers involved in nationwide class actions or multi-plaintiff lawsuits can now stay together in one federal case even when some plaintiffs' individual claims are too small to qualify for federal court on their own, as long as one plaintiff's claim is large enough and the claims are related. This lowers a hurdle that previously forced many smaller claims out of federal court.
What changes now
The Eleventh Circuit's ruling allowing the Exxon dealers' class action to proceed stands. The First Circuit's ruling against the Star-Kist family is reversed, and that case goes back to the lower courts so the family's claims can be heard alongside the injured girl's claim. This is a final, on-the-merits interpretation of the supplemental-jurisdiction statute that will guide how federal courts handle multi-plaintiff diversity suits going forward.
What this does not decide
The ruling does not change the rule that all parties on opposite sides of a lawsuit must be citizens of different states (complete diversity) — that requirement still defeats jurisdiction over an entire case. It applies only to the separate dollar-amount requirement, and only when the other jurisdictional elements, including complete diversity, are already satisfied.
Concurrences and dissents
Dissent — Justice Stevens
Justice Stevens argued that the majority's confident declaration that the statute is 'unambiguous' was itself questionable, given how thoroughly Justice Ginsburg's dissent undermined it. He argued judges should be more willing to consult legislative history, and that the House Report here powerfully confirmed Congress meant only to overturn Finley, not Clark and Zahn, making the majority's broader reading mistaken.
Dissent — Justice Ginsburg
“The Court adopts a plausibly broad reading of § 1367, a measure that is hardly a model of the careful drafter’s art.”Ginsburg's assessment that the statute's wording does not clearly compel the majority's broad result.
Justice Ginsburg argued the statute's text is better read to require that a case first satisfy all of Section 1332's requirements, including the dollar amount for every plaintiff, before supplemental jurisdiction can attach at all. Under her reading, Clark and Zahn would survive, and Congress's only goal in 1990 was to reverse Finley while otherwise preserving the older law and rules around joinder.
How the Court got there
The legal reasoning, step by step
- The Court started from the settled principle that once a federal court has original jurisdiction over at least one claim in a case, it may exercise 'supplemental jurisdiction' — the power to also hear closely related claims that wouldn't qualify for federal court on their own — as established in the 1966 case Mine Workers v. Gibbs.
- The Court explained that before 1990, a separate line of decisions (Clark v. Paul Gray and Zahn v. International Paper) required every single plaintiff in a case to independently meet the minimum dollar amount for federal diversity cases, an amount now set at $75,000.
- The Court read the text of the 1990 supplemental-jurisdiction statute, Section 1367, and concluded that once a complaint contains at least one claim meeting that dollar threshold, the whole lawsuit qualifies as an 'action' over which the court has original jurisdiction — meaning the door is open to also hear the smaller, related claims of other plaintiffs.
- The Court rejected two competing theories: an 'indivisibility theory,' under which every claim in a complaint would have to independently qualify, and a 'contamination theory,' under which one plaintiff's inadequate claim would taint the whole case. The Court found neither theory consistent with the statute's broad wording or with the narrow list of exceptions Congress actually wrote into the statute.
- Applying this reading, the Court concluded that Section 1367's text plainly displaced the older rule from Clark and Zahn requiring every plaintiff to independently meet the dollar threshold, since Congress listed specific, narrower exceptions to the broad grant of supplemental jurisdiction rather than a blanket bar for undersized claims.
- The Court declined to let legislative committee reports override this reading of the statutory text, finding the text unambiguous and the committee history itself inconsistent on the point.
Doctrinal impact
Cases affected by this decision
Overrules Zahn v. International Paper Co. (414 U. S. 291)
The Court held Section 1367's text overruled Zahn's rule that every class member must meet the dollar threshold.
Overrules Clark v. Paul Gray, Inc. (306 U. S. 583)
The Court held Section 1367 overruled Clark's requirement that every plaintiff independently satisfy the dollar amount.
Overrules Finley v. United States (490 U. S. 545)
The Court confirmed Section 1367 already overturned Finley's bar on jurisdiction over added parties without independent grounds.
Reaffirms Mine Workers v. Gibbs (383 U. S. 715)
The Court relied on Gibbs as the foundation for allowing related claims to be heard together in one case.
Reaffirms Chicago v. International College of Surgeons (522 U. S. 156)
The Court applied this removal-jurisdiction case to support reading 'civil action' as satisfied by a single qualifying claim.