Civil procedure: Amount in controversy + Supplemental jurisdiction + Removal jurisdiction + Class Action Fairness Act of 2005

Amount in controversy (sometimes called jurisdictional amount) is a term used in civil procedure to denote the amount at stake in a lawsuit, in particular in connection with a requirement that persons seeking to bring a lawsuit in a particular court must be suing for a certain minimum amount (or below a certain maximum amount) before that court may hear the case.

United States.

In federal courts.

Diversity jurisdiction.

In United States federal courts, the term currently applies only to cases brought under diversity jurisdiction, meaning that the court is able to hear the case only because it is between citizens of different states. In such cases, the US Congress has decreed in 28 USC § 1332(a) that the court may hear such suits only where "the matter in controversy exceeds the sum or value of $75,000." This amount represents a significant increase from earlier years.

Congress first established the amount in controversy requirement when it created diversity jurisdiction in the Judiciary Act of 1789, pursuant to its powers under Article 3 of the US Constitution, the amount being $500. It was raised to $2,000 in 1887, to $3,000 in 1911, to $10,000 in 1958, to $50,000 in 1988, and finally to the current $75,000 in 1996.

The use of the word "exceeds" in Section 1332 implies that the amount in controversy must be more than $75,000; a case removed from state court to federal court must be remanded back to state court if the amount in controversy is exactly $75,000.00.

Federal question jurisdiction.

Congress did not create a consistent federal question jurisdiction, which allows federal courts to hear any case alleging a violation of the Constitution, laws, and treaties of the United States, until 1875, when Congress created the statute which is now found at 28 USC § 1331: "The district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States." At that time, such cases had the same amount of controversy requirement as the diversity cases. Congress eliminated this requirement in actions against the United States in 1976 and in all federal question cases in 1980.

Aggregation of claims.

Where a single plaintiff has multiple unrelated claims against a single defendant, that plaintiff can aggregate those claims – that is, add the amounts together – to satisfy the amount in controversy requirement. In cases involving more than one defendant, a plaintiff may aggregate the amount claimed against multiple defendants “only if the defendants are jointly liable.” Middle Tennessee News Company Incorporated v Charnel of Cincinnati, Incorporated (2001). However, “if the defendants are severely liable, the plaintiff must satisfy the amount in controversy required against each individual defendant.” The 5–4 decision in Exxon Mobil Corporation v Allapattah Services Incorporated, (2005), held that a federal court has supplemental jurisdiction over claims of other plaintiffs who do not meet the jurisdictional amount for a diversity action, when at least one plaintiff in the action does satisfy the jurisdictional amount.