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Monday, May 10, 2010

Supplemental Jurisdiction Saves the Day for Amount in Controversy Deficiencies in Multiple Plaintiff Cases

In Exxon Mobil Corp. v. Allapattah Services, Inc., 545 U.S. 546 (2005), the Court held that “where the other elements of jurisdiction are present and at least one named plaintiff in the action satisfies the amount-in-controversy requirement, §1367 does authorize 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 jurisdictional amount specified in the statute setting forth the requirements for diversity jurisdiction.” The Supreme Court concluded that §1367(a) unambiguously overruled its previous holding in Zahn v. International Paper Co., 414 U.S. 291, 294-95 (1973), and held that because several of the plaintiffs satisfied the amount-in-controversy requirement of § 1332(a), and because the claims of the other plaintiffs undeniably arose out of the same case or controversy over which the district court had original jurisdiction, supplemental jurisdiction over the claims of all the named plaintiffs was proper. See also Engstrom v. Mayfield, 195 Fed.Appx. 444, 448, 2006 WL 2456948 (6th Cir. 2006)(if any plaintiff satisfies the amount-in-controversy requirement of § 1332(a), the claims of other plaintiffs that arise out of the same case or controversy are properly the subject of supplemental jurisdiction).