Exxon Mobil Corp. v. Allapattah Services, Inc.

Exxon Mobil Corp. v. Allapattah Services, Inc., 545 U.S. 546 (2005), was a case in which the Supreme Court of the United States held that 28 U.S.C. § 1367 permits supplemental jurisdiction over joined claims that do not individually meet the amount-in-controversy requirements of § 1332, provided that at least one claim meets the amount-in-controversy requirements.

Background

Federal Courts are courts of limited subject matter jurisdiction. The limited jurisdiction is created by specific grants contained in Article III, Section 2 of the United States Constitution, and Congress is granted authority to further limit the jurisdiction of the federal court. Congress cannot grant jurisdiction to the federal courts that would be prohibited by the Constitution, but they have the authority to further limit (narrow the scope of jurisdiction). Historically, Congress has authorized exercise of two primary types of jurisdiction in civil cases: federal-question jurisdiction (28 U.S.C. § 1331), which grants jurisdiction over civil cases wherein the plaintiff seeks adjudication on the grounds of some Federal statute or rule; and diversity jurisdiction (28 U.S.C. § 1332), wherein the plaintiffs are from different states of the Union.

In order to limit the number of cases in federal court, both of these forms of jurisdiction once required that the amount of money, or equivalent monetary value in the case of non-monetary relief, must reach a certain threshold. These requirements were called amount-in-controversy requirements, and at the time of Exxon, only diversity jurisdiction cases retained such requirements.

Simple grants of jurisdiction over plaintiffs' original claims under § 1331 and § 1332 would present problems for the efficient adjudication of disputes; a federal court may not have subject-matter jurisdiction over potential counter-claims by defendants, or other claims such as impleader and cross-claims.