In the case of Snyder v. Harris, 1968, the U.S. Supreme Court ruled that plaintiffs cannot aggregate their claims in order to meet the jurisdictional amount required for diversity jurisdiction in federal court. The case involved a group of policyholders who sued an insurance company and its officers for alleged fraud and misrepresentation regarding dividends on life insurance policies. Each plaintiff's claim was less than $10,000 (the minimum amount necessary to establish federal jurisdiction), but they argued that their combined total exceeded this threshold. However, the Supreme Court held that each individual plaintiff must independently satisfy the monetary requirement unless they are enforcing a single title or right in which they have a common undivided interest.

In the dissenting opinion for Snyder v. Harris, Justice Douglas argued that the majority's decision to limit class action lawsuits was a misinterpretation of Rule 23 in Federal Rules of Civil Procedure. He believed that this rule should be interpreted broadly to allow more people access to legal remedies and not restrict it as per the majority’s interpretation. According to him, limiting class actions would disproportionately affect those with smaller claims who may not have resources or motivation to pursue individual litigation. Moreover, he contended that such limitations could potentially flood courts with numerous similar cases which could have been efficiently handled as a single class-action lawsuit. Thus, he disagreed with the majority's view on grounds of both justice accessibility and judicial efficiency.