Sixth Circuit Applies Allapattah Services to Uphold Diversity Jurisdiction over Insufficient Supplemental Claims

The Sixth Circuit in Engstrom v. Mayfield, Slip Copy, 2005 WL 3448278 (6th Cir. Dec. 15, 2005) (Unpuplished Opinion) recently upheld the exercise of supplemental jurisdiction over jurisdictionally insufficient claims asserted by plaintiffs joined under Rule 20. Although one plaintiff had a claim that satisfied the amount in controversy, the remainder did not. However, because the plaintiffs were proceeding jointly against the defendants as Rule 20 parties, the court concluded that under Exxon Mobil Corp. v. Allapattah Services, Inc., --- U.S. ----, ----, 125 S.Ct. 2611, 2615, 162 L.Ed.2d 502 (2005), 28 U.S.C. sec. 1367 provided for supplemental jurisdiction over the jurisdictionally insufficient claims so long as one plaintiff had a claim that satisfied the amount-in-controversy requirement.