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Civil Procedure Keyed to Babcock
Exxon Mobil Corp. v. Allapattah Services, Inc.
Citation:
545 U.S. 546 (2005)ProfessorTodd Berman
CaseCast™ – "What you need to know"
Facts
Consolidation of two cases to resolve circuit split regarding amount in controversy in diversity jurisdiction cases. Some of the class members’ claims did not meet the amount in controversy requirement for diversity jurisdiction, but the Eleventh Circuit Court of Appeals allowed joinder of the claims and allowed the case to proceed so long as one of the claims met the amount in controversy requirement. The second case involved a young girl that sued Starkis for an injury she sustained when she cut herself on one of their cans. The girl attempted to join her parents as Plaintiffs but the district court held that none of the parties had damages that met the amount in controversy requirement. On appeal, the First Circuit found that the parents’ claims did not meet the requirement and therefore could not be joined, but that the girl’s claim was and could be brought on its own. The United States Supreme Court granted certiorari to resolve the circuit split.
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