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Note: 

Federal Jurisdiction—A Plaintiff Can Aggregate His Federal and Nonfederal Claims Against the Same Defendant in Order to Meet the Jurisdictional Amount Requirement for Federal Diversity Jurisdiction.  Hales v. Winn-Dixie Stores, Inc., 500 F.2d 836 (4th Cir. 1974), 53 TEXAS L. REV. 604 (1975). 

In Hales, the court held that when diversity of citizenship exists, a plaintiff can aggregate his federal and nonfederal claims in order to meet the amount in controversy requirement for diversity jurisdiction.  In this note, the author argues that the amount in controversy is a less legitimate basis for federal jurisdiction than is the “common nucleus of operative fact” test, in which a federal court will decide a state claim if it is closely related to a pending federal claim.  The author suggests that the Supreme Court should revise its statement of the common nucleus test to make it available more often so that courts will not be tempted to liberalize the amount in controversy requirement in order to do justice.