Zahn v. Int'l Paper Co.

414 U.S. 291, 94 S. Ct. 505 (1973)



When two or more plaintiffs, having separate and distinct demands, unite for convenience and economy in a single suit, it is essential that the demand of each be of the requisite jurisdictional amount; but when several plaintiffs unite to enforce a single title or right, in which they have a common and undivided interest, it is enough if their interests collectively equal the jurisdictional amount. 


Petitioners, owners of property fronting on Lake Champlain, brought a diversity action in the district court seeking to recover damages for respondent's pollution of the lake. Petitioners sought to maintain a class action under Fed. R. Civ. P. 23(b), each alleging damages in excess of the jurisdictional amount pursuant to 28 U.S.C.S. § 1332. The district court refused to certify the suit as a class action because each unnamed plaintiff did not individually satisfy the jurisdictional amount requirements. The court of appeals affirmed. On certiorari, the United States Supreme Court affirmed.


Did the petitioners individually satisfy the jurisdictional requirements in order to constitute a class action suit? 




It was held that diversity class actions involving plaintiffs with separate and distinct claims were subject to the usual rule that a Federal District Court could assume jurisdiction over only those plaintiffs presenting claims exceeding the jurisdictional amount requirement of 28 USCS 1332(a), and thus the instant case could not be maintained as a class action, since even though the named plaintiffs each satisfied the jurisdictional amount requirement, nevertheless the unnamed plaintiffs did not individually satisfy such requirement.

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