Regarding Sec. 1367(b) and Rule 19 plaintiffs:
- if original jurisdiction is based on diversity and properly fulfilled under 1332, and
- adding a Rule 19 plaintiff would not destroy complete diversity
- But the Rule 19 plaintiff's claim does not meet the amount in controversy requirement;
But it seems the text of 1367(b) would bar Rule 19 or 24 plaintiffs whose claims are not greater than $75k, even though the principle of the amount in controversy is the same. Is this why the Exxon Court hypothesized that perhaps Congress wanted a higher threshold for claims from these types of "essential" plaintiffs?
Yes. Exxon required additional analysis because the situation--claims by persons joined under Rule 20--was not listed in § 1367(b). But a person to be joined under Rule 19 is listed in an express exclusion in § 1367(b). So those claims are not within supplemental jurisdiction, regardless if the problem is lack of complete diversity or less than $ 75k being sought.