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Civil Procedure Keyed to Spencer
Exxon Mobil Corp. v. Allapattah Services, Inc.
Citation:
545 U.S. 546 (2006)
ProfessorTodd Berman
CaseCast™ – "What you need to know"
Facts
Two cases were consolidated to resolve a circuit split. In the first (Allapattah Services, Inc. v. Exxon Corp.), 10,000 Exxon dealers filed a class-action suit, claiming to be overcharged for fuel they purchased from Exxon. Some plaintiffs met the amount in controversy requirement, but some did not. The Eleventh Circuit held that federal courts could exercise supplemental jurisdiction over all plaintiffs.
In the second case (Rosario Ortega v. Star-Kist), a nine-year-old girl allegedly injured her finger while opening a tuna can. She and her family sued Star-Kist, the canning company. The injured girl satisfied the amount in controversy requirement, but her family did not. The First Circuit held that a federal court could not exercise supplemental jurisdiction over all plaintiffs, since some did not satisfy the requirement. The Supreme Court agreed to resolve the issue.
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