Adams v. Grossmont Cuyamaca Community College District

CourtDistrict Court, S.D. California
DecidedMarch 15, 2024
Docket3:23-cv-01220
StatusUnknown

This text of Adams v. Grossmont Cuyamaca Community College District (Adams v. Grossmont Cuyamaca Community College District) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Adams v. Grossmont Cuyamaca Community College District, (S.D. Cal. 2024).

Opinion

1 UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF CALIFORNIA 3 Alysha ADAMS, et al., Case No.: 23-cv-1220-AGS-DDL 4 Plaintiffs, ORDER DENYING MOTION TO 5 v. REMAND (ECF 7) AND GRANTING MOTION TO DISMISS (ECF 2) 6 GROSSMONT CUYAMACA COMMUNITY COLLEGE DISTRICT, 7 et al., 8 Defendants. 9 10 Plaintiffs sued their community-college employers over COVID-19 vaccine 11 mandates. The defense removed the case here, and plaintiffs now seek remand back to state 12 court. The defense meanwhile moves to dismiss based on mootness and failure to state a 13 claim. 14 BACKGROUND 15 This case’s 31 defendants include three community-college districts, their governing 16 boards, and various presidents, chancellors, and employees sued “in their official 17 capacities only.” (ECF 1, at 11–13.) In late 2021, defendants “adopted a COVID-19 18 vaccine requirement” compelling employees to “obtain the vaccine or submit an exemption 19 thereto.” (Id. at 14, 17, 35–36.) Of the six plaintiffs, five requested religious exemptions, 20 which were granted, and one sought a medical exemption, which was not. (Id. at 14–40.) 21 All six claim they were denied reasonable accommodations. (Id.) 22 In March 2023, plaintiffs sued in state court, just a few months before defendants 23 repealed their vaccine mandates. (See ECF 1, at 58; ECF 2-2 at 16, 24, 33.) They allege 24 that: the vaccine mandate is preempted by state law (claim 1); the vaccine rules were ultra 25 vires acts (claim 2); the mandate amounts to religious discrimination under the 26 First Amendment in violation of 42 U.S.C. § 1983 (claims 3 and 4); and defendants failed 27 to accommodate—and subjected them to disparate treatment because of—their religious 28 beliefs in violation of Title VII of the Civil Rights Act (claims 5–9). (See ECF 1, at 41–55.) 1 DISCUSSION 2 MOTION TO REMAND 3 Plaintiffs move to remand this case to state court, arguing: (1) defendants’ 4 Eleventh Amendment immunity deprives this Court of original jurisdiction; (2) the 5 removal was untimely; and (3) the state-law claims predominate over the federal ones. 6 A. Eleventh Amendment Immunity 7 Plaintiffs reason that if defendants have Eleventh Amendment immunity, as the 8 defense insists, then this Court has “no subject matter or original jurisdiction” and removal 9 was “improper.” (ECF 7, at 4.) That premise is flawed. Eleventh Amendment immunity is 10 “an affirmative defense,” not an assertion of “lack of subject matter jurisdiction.” Miles v. 11 State of California, 320 F.3d 986, 988–89 (9th Cir. 2003). And federal courts have 12 “jurisdiction” over “all civil actions arising under” federal law, such as many claims here. 13 See 28 U.S.C. § 1331. Any immunity defense does not affect this Court’s jurisdiction. The 14 remand motion on that ground is denied. 15 B. Timeliness of Removal 16 Next, plaintiffs maintain that the removal was late. A removal notice must be filed 17 “within 30 days” of service, as “governed by state law.” Whidbee v. Pierce County, 18 857 F.3d 1019, 1023 (9th Cir. 2017) (citing 28 U.S.C. § 1446(b)). The issue here is when 19 “service” was complete. More precisely, the question is: If the defense waives standard 20 service, when is service effective? 21 In this case, plaintiffs requested that defense counsel “accept service upon you by 22 email.” (ECF 13-1, at 4.) All counsel agreed, though one attorney asked that plaintiffs “also 23 provide notice(s) of acknowledgment.” (Id. at 6, 8, 11.) On May 10, 2023, plaintiffs 24 emailed defense counsel the state-court summons and complaint. (ECF 7-1, at 1–4.) Three 25 weeks later, on May 31, each defense counsel signed and returned a “Notice and 26 Acknowledgment of Receipt.” (ECF 1, at 83, 85, 87; ECF 11, at 11.) The case was 27 removed on June 30, 2023. 28 1 According to plaintiffs, service was complete when the defense accepted the emailed 2 pleadings on May 10, and thus the 30-day deadline expired weeks before the June 30 3 removal. (See ECF 13, at 1–3.) Defendants, on the other hand, contend that service was not 4 effective until they “signed and returned” the acknowledgment on May 31, which means 5 they timely removed this action exactly 30 days later. (ECF 1, at 83, 85, 87; ECF 11, at 11.) 6 It is “axiomatic that defects in service may be waived by a responding party either 7 expressly or by appearing in an action.” Ammec Invs., Inc. v. Ifaomilekun, LLC, No. 8 B314854, 2023 WL 3473663, at *4 (Cal. Ct. App. May 16, 2023). But when service 9 becomes effective after such a waiver is a matter of debate in California. Relying on 10 California’s “Service by mail” rules, the defense believes that service is effective “when a 11 Notice and Acknowledgment of Receipt [of summons] is executed and returned.” (See 12 ECF 11, at 12 (citing, among others, Cal. Civ. Proc. Code § 415.30).) But those rules cover 13 service by “first-class mail or airmail,” not by email. See Cal. Civ. Proc. Code § 415.30(a). 14 The reality is that statutory law offers little guidance here, because California lacks formal 15 procedures for email service or for waiving service. Compare Cal. Civ. Proc. Code 16 §§ 415.10–415.95 (California’s summons rules, which do not mention waiver) with Fed. 17 R. Civ. P. 4(d) (federal summons rule, which provides procedure to “waive service of a 18 summons”). And the state courts have not yet resolved how to deal with service-by-email 19 agreements like the one here. 20 “Absent controlling authority from the state supreme court, a federal court must 21 predict how the highest state court would decide the state law issue . . . .” Camenzind v. 22 California Exposition & State Fair, 84 F.4th 1102, 1114 (9th Cir. 2023) (cleaned up). 23 Happily, this Court need not hazard such a prediction. There are only two ways that the 24 California Supreme Court is likely to resolve this legal dispute, and both support removal. 25 First, California may conclude that agreeing to “email” service—without more—is a 26 limited waiver of the “Service by mail” rules. That is, it waives the requirement of delivery 27 by “first-class mail or airmail” (in favor of email), but it retains the other procedural 28 provisions for mail service. See Cal. Civ. Proc. Code § 415.30(a). Under this scenario, then, 1 service would be “deemed complete on the date a written acknowledgement of receipt of 2 summons [wa]s executed” and “returned to the sender,” which was May 31, 2023. See 3 § 415.30(c). At least one federal court has adopted this view. See Hillman v. PacifiCorp, 4 No. 2:21-cv-00848-MCE-CKD, 2022 WL 597583, at *5 (E.D. Cal. Feb. 28, 2022) (holding 5 that email service was effective “on the date the ‘acknowledgment of receipt of summons 6 [wa]s executed and returned’” (citing, in part, Cal. Civ. Proc. Code § 415.30(c))). 7 On the other hand, the state Supreme Court may decide that an email-service 8 agreement completely waives the “Service by mail” rules, and thus the effective date of 9 service is governed by the terms of the waiver itself.

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Bluebook (online)
Adams v. Grossmont Cuyamaca Community College District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/adams-v-grossmont-cuyamaca-community-college-district-casd-2024.