Exxon

Facts of the Case:

In 1991 about 10,000 Exxon dealers sued Exxon Corporation in federal court, alleging that the
corporation had engaged in an extensive scheme to overcharge them for fuel. A jury found in favor of
the plaintiffs, but the District Court judge certified the case for review on the question of supplemental
jurisdiction. Some of the multiple plaintiffs in the case had claims that did not meet the minimum
amount necessary to qualify for federal diversity jurisdiction (currently $75,000). In 1990 Congress had
enacted 28 U.S.C. Section 1367, overturning Finley v. United States, which had narrowly interpreted
federal courts' power to confer supplementary jurisdiction on related claims. The question for the
District Court was whether Section 1367 also overturned Zahn v. International Paper Co., which ruled
that each plaintiff had to separately meet the minimum amount-in-controversy requirement. The
District Court accepted the plaintiffs' argument that Section 1367 gave federal courts power to exercise
supplemental jurisdiction over plaintiffs with related claims, even if some plaintiffs' claims did not
meet the required amount. On appeal, the Eleventh Circuit Court of Appeals upheld the District Court's
ruling on supplemental jurisdiction. However, this ruling conflicted with the ruling of another Circuit,
which had taken the opposite view of Section 1367's scope (see Ortega v. Star-Kist Foods, No. 04-79).
The Supreme Court granted certiorari and consolidated the cases for argument.
Question:
In a civil action where one plaintiff's claim satisfies the minimum amount-in-controversy requirement
for federal diversity jurisdiction, and another plaintiff's related claim does not, does 28 U.S.C. Section
1367 allow federal courts to exercise supplemental jurisdiction over the claim that is less than the
required amount?
Conclusion:
Yes. In a 5-4 decision, the Court ruled that as long one plaintiff meets the amount-in-controversy
requirement for federal jurisdiction, Section 1367 authorizes federal courts to exercise supplemental
jurisdiction over related claims even if they do not meet the requirement. The majority opinion by
Justice Anthony Kennedy held that courts only need to determine whether they have original
jurisdiction over one of the claims in a case. If they do, courts can then decide to extend supplemental
jurisdiction to the other related claims. The Justices ruled that to require each claim in a civil action to
meet the requirement would be "inconsistent with the whole notion of supplemental jurisdiction." The
Court based its ruling on the "unambiguous[]" text of the statute, saying "the authoritative statement is
the statutory text, not the legislative history or any other extrinsic material." Justice Stevens, joined by
Justice Breyer, wrote a dissenting opinion arguing that the Court should have consulted the legislative
history of Section 1367. Justice Ginsburg, joined by Justices Stevens, O'Connor, and Breyer, wrote a
dissent arguing for a narrower interpretation of Section 1367 that would not overturn Zahn