Case Citator › Meritcare Incorporated Meritcare Ventures, Inc. Quinlan Medical, Inc. v. St. Paul Mercury Insurance Company

Meritcare Incorporated Meritcare Ventures, Inc. Quinlan Medical, Inc. v. St. Paul Mercury Insurance Company

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Third Circuit
Citation
166 F.3d 214
Decided
Confirmed treatments
1
Flagged citations read
40 of 40
Citing cases (total)
40
Treatment dates
2005
Overruled in part
A reviewed court has overruled part of this case’s holding. Meritcare Inc. v. St. Paul Mercury Insurance Co. was overruled in part on supplemental jurisdiction; the confirmed treatment is listed below. All 40 flagged citations have been read.
More on how this was screened

The Supreme Court held that 28 U.S.C. § 1367 permits jurisdiction over a related claim below the amount-in-controversy minimum when at least one named plaintiff meets that minimum and the other jurisdictional requirements are satisfied. Later courts continue to apply Meritcare's separate rules on examining subject matter jurisdiction and measuring the amount in controversy.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

40 later cases cite Meritcare Incorporated Meritcare Ventures, Inc. Quinlan Medical, Inc. v. St. Paul Mercury Insurance Company; 40 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Meritcare Incorporated Meritcare Ventures, Inc. Quinlan Medical, Inc. v. St. Paul Mercury Insurance Company?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The Supreme Court rejected Meritcare's rule that every separately joined diversity plaintiff must independently satisfy the amount-in-controversy minimum.

    Exxon Mobil Corp. v. Allapattah Services, Inc. · Supreme Court of the United States · filed

    The omission of Rule 20 plaintiffs from the list of exceptions in § 1367(b) may have been an “unintentional drafting gap,” Meritcare, 166 F. 3d, at 221, and n. 6. If that is the case, it is up to Congress rather than the courts to fix it. The omission may seem odd, but it is not absurd. ... We hold that § 1367 by its plain text overruled Clark and Zahn and authorized supplemental jurisdiction over all claims by diverse parties arising out of the same Article III case or controversy, subject only to enumerated exceptions not applicable in the cases now before us.
    Read the full opinion on CourtListener →

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