Amitay v. Jews for Jesus, Inc.

CourtDistrict Court, N.D. California
DecidedApril 17, 2025
Docket3:25-cv-01258
StatusUnknown

This text of Amitay v. Jews for Jesus, Inc. (Amitay v. Jews for Jesus, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Amitay v. Jews for Jesus, Inc., (N.D. Cal. 2025).

Opinion

1 2 3 4 IN THE UNITED STATES DISTRICT COURT 5 FOR THE NORTHERN DISTRICT OF CALIFORNIA 6 7 ARIEL ZVOLON AMITAY, Case No. 25-cv-01258-MMC

8 Plaintiff, ORDER GRANTING PLAINTIFF'S 9 v. MOTION TO REMAND; DENYING PLAINTIFF'S REQUEST FOR 10 JEWS FOR JESUS, INC., ATTORNEY'S FEES AND COSTS; VACATING HEARING Defendant. 11

12 13 Before the Court is plaintiff Ariel Zvolon Amitay's ("Amitay") "Motion to Remand to 14 Superior Court [and] Request for Attorneys' Fees and Costs," filed March 7, 2025. 15 Defendant Jews for Jesus, Inc. ("Jews for Jesus") has filed opposition, to which Amitay 16 has replied. Having read and considered the papers filed in support of and in opposition 17 to the motion and request, the Court deems the matters appropriate for determination on 18 the parties' respective written submissions, VACATES the hearing scheduled for April 25, 19 2025, and rules as follows. 20 In the operative complaint, filed in California state court on December 24, 2024, 21 Amitay asserts four Causes of Action, titled, respectively, "Defamation," "False Light," 22 "Intentional Infliction of Emotional Distress," and "Negligent Infliction of Emotional 23 Distress," which claims are based on his allegation that Jews for Jesus "uploaded photos 24 of Amitay on their social media pages" and "included a caption" that "falsely express[ed] 25 that Amitay supported [Jews for Jesus's] religious views." (See Compl. ¶ 14.) 26 On February 5, 2025, Jews for Jesus removed the action, on the asserted ground 27 that a federal question exists or, alternatively, that diversity jurisdiction exists. By the 1 Jesus cannot remove on the basis of diversity due to its status as a citizen of California. 2 The Court considers the two issues, in turn. 3 A. Federal Question 4 As noted, Amitay asserts four Causes of Action. Each Cause of Action is, on its 5 face, a claim under state law. In its Notice of Removal, however, Jews for Jesus asserts 6 that a federal question exists, which it identifies as follows: "This case involves the free 7 speech and free exercise of religion of a religious non-profit organization engaged in 8 public discourse on matters of public interest, and necessarily requires the consideration 9 and adjudication of issues related to the First Amendment to the United States 10 Constitution, which protects these fundamental rights." (See Notice of Removal ¶ 33.) 11 Although, as Jews for Jesus points out, a defendant can raise in district court a 12 First Amendment defense to state law claims arising from the defendant's speech-related 13 conduct, such protection does not itself give rise to federal jurisdiction. See, e.g., Snyder 14 v. Phelps, 562 U.S. 443,448-50, 458-60 (2011) (finding, in diversity action, First 15 Amendment barred state law claims arising from picketing in public place); Vess v. Ciba- 16 Geigy Corp. USA, 317 F.3d 1097, 1109 (9th Cir. 2003) (holding, in diversity action, 17 "[m]otions to strike a state law claim under California's anti-SLAPP statute may be 18 brought in federal court"). Rather, contrary to Jews for Jesus's argument, the existence 19 of a federal defense to a state law claim cannot create a federal question, as "a 20 defendant cannot, merely by injecting a federal question into an action that asserts what 21 is plainly a state-law claim, transform the action into one arising under federal law, 22 thereby selecting the forum in which the claim shall be litigated." See Caterpillar Inc. v. 23 Williams, 482 U.S. 386, 399 (1987) (holding "Congress has long since decided that 24 federal defenses do not provide a basis for removal"). 25 In its opposition, Jews for Jesus identifies what it contends is another federal 26 question. Specifically, it asserts, "[t]o the extent that Amitay seeks to recover damages 27 arising from the reproduction or display of the photograph, rather than from an alleged 1 Opp. at 24:4-6.) 2 A state law claim is preempted by the Copyright Act where the "subject matter" of 3 the claim "falls within the subject matter of copyright," such as "pictorial . . . works," and 4 "the rights asserted under state law are equivalent to the rights contained in [the 5 Copyright Act]," such as the right to distribute copies of photographs. See Laws v. Sony 6 Music Entertainment, Inc., 448 F.3d 1134, 1137-38 and nn. 1, 3 (9th Cir. 2008). Here, 7 however, Jews for Jesus cites to no section of the Complaint in which Amitay challenges 8 the reproduction or display of the photograph in and of itself or otherwise seeks to base 9 recovery on a right equivalent to one in the Copyright Act. Rather, Amitay, who does not 10 allege he has any rights in the photograph used by Jews for Jesus, seeks to recover 11 damages based on alleged damage to his reputation resulting from an assertedly false 12 statement (see Compl. ¶¶ 21-23, 25-27, 29) as well as damages due to emotional 13 distress he claims resulted from the assertedly false statement (see Compl. ¶¶ 29-31, 35- 14 37). The rights protected by defamation law and by the law prohibiting the intentional 15 infliction of emotional distress are not, at least in the context of the instant case, rights 16 equivalent to those under the Copyright Act. See Laws, 448 F.3d at 1143 (explaining 17 state law claims not preempted by Copyright Act where claims "protect rights which are 18 qualitatively different from the copyright rights") (internal quotation and citation omitted); 19 see also, e.g., Anderson v. Jackson, 2005 WL 8166024, at *4 (C.D. Cal. August 8, 2005) 20 (holding slander claim not preempted, where claim based on false statement about 21 plaintiffs, an "'extra element' that renders [the slander claim] qualitatively different from a 22 claim for copyright infringement"); Sturdza v. United Arab Emirates, 281 F.3d 1287, 1305- 23 06 (D.C. Cir. 2002) (holding claim for intentional infliction of emotional distress not 24 preempted, where based on conduct other than defendant's use of plaintiff's work). 25 Accordingly, Jews for Jesus has failed to show any of Amitay's claims present a 26 federal question. 27 B. Diversity Jurisdiction 1 $75,000, see 28 U.S.C. § 1332(a), and the action is between "citizens of a State and 2 citizens or subjects of a foreign state," see 28 U.S.C. § 1332(a)(2). 3 Here, Amitay seeks recovery of, inter alia, "punitive and exemplary damages of at 4 least $5,000,000" (see Compl., Prayer for Relief, ¶ D), and Amitay does not dispute Jews 5 for Jesus's allegations that it is a citizen of California and he is a citizen of Israel (see 6 Notice of Removal ¶¶ 7-8). Amitay contends, however, remand is required in light of the 7 forum defendant rule, under which "[a] civil action otherwise removable solely on the 8 basis of [diversity] may not be removed if any of the parties in interest properly joined and 9 served as defendants is a citizen of the State in which such action is brought." See 28 10 U.S.C. § 1441(b)(2). In response, Jews for Jesus argues it was not "properly" served 11 prior to removal, and, consequently, that the forum defendant rule is not applicable. 12 District courts have disagreed as to whether a forum defendant may engage in a 13 "snap removal," i.e., a removal where the defendant has not yet been served.

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Amitay v. Jews for Jesus, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/amitay-v-jews-for-jesus-inc-cand-2025.