Snyder v. Harris – Case Brief
Snyder v. Harris, 394 U.S. 332 (1969).
Facts: A class action suit brought under diversity was filed in federal court. Each individual claim was less than the jurisdictional amount. The circuits were split regarding whether to allow aggregation of claims to meet the amount in controversy requirement for diversity.
Issue: May separate and distinct claims under a class action suit be aggregated to meet diversity jurisdictional amounts?
Holding and Rule – Black: No. Separate and distinct claims under a class action suit may not be aggregated to meet diversity jurisdictional amounts. The court acknowledged that aggregation had been permitted where a single plaintiff sought to aggregate two or more claims against a single defendant, and where two or more plaintiffs united to enforce a single title or right in which they had a common and undivided interest. The court held that the adoption of the 1966 amendment to Rule 23 did not change the doctrine.
Dissent – Fortas: Permitting aggregation in class action suits does not violate the principle expressed in Rule 82 and inherent in the procedure for the promulgation and amendment of the FRCP. FRCP 23 provides that nominally separate and legally several claims of individuals may be so similar that they can be tried together as if they were a single claim. Aggregation should be permitted when that determination is made under the painstaking demands of FRCP 23.
Notes: Note that claims can be aggregated if two or more plaintiffs unite to enforce a single title or right in which they have a common and undivided interest.