28 U.S.C.S. § 1332 grants jurisdiction to United States district courts of suits between citizens of different states where the matter in controversy exceeds the sum or value of $ 10,000. Separate and distinct claims presented by and for various claimants in a class action may not be added together to provide the $ 10,000 jurisdictional amount in controversy.
In two separate actions, plaintiff litigants filed claims on his or her own behalf and on behalf of all others similarly situated. In the case before the first appellate court, plaintiff shareholder sought $ 8,740 in damages for herself, but contended that the aggregate claims of other shareholders exceeded the jurisdictional amount of $ 10,000. The appellate court affirmed the dismissal of the action for lack of jurisdiction. The second appellate court held that separate and distinct claims brought together for a class action could now be aggregated to meet the $ 10,000 required for diversity jurisdiction. The case was elevated on certiorari to the Supreme Court of the United States.
Can separate and distinct claims presented by and for various claimants in a class action lawsuit be added together to provide the $ 10,000 amount to acquire diversity jurisdiction?
The Court affirmed the decision of the first appellate court that did not allow aggregation of amounts in a class action lawsuit to meet the $ 10,000 amount in controversy required for diversity jurisdiction. The Court held that the amendments to Fed. R. Civ. P. 23, making new guidelines for class action lawsuits, did not effect a change in the scope of diversity jurisdiction by allowing claimants to aggregate amounts. The Court declined to overrule the long established statutory interpretation that the jurisdictional amount for federal court diversity jurisdiction could not be reached through the aggregation of separate and distinct claims.