Angela Madatovian v. Bayer Healthcare LLC

• Court: District Court, C.D. California
• Decided: March 11, 2025
• Docket: 2:24-cv-10232
• Status: Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 ANGELA MADATOVIAN, Case No. 2:24-cv-10232-FLA (MAAx)

12 Plaintiff, ORDER TO SHOW CAUSE WHY 13 v. ACTION SHOULD NOT BE REMANDED FOR LACK OF 14 EQUITABLE JURISDICTION BAYER HEALTHCARE LLC, 15 Defendant. 16 17

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20 21 22 23 24 25 26 27 28 1 ORDER 2 “In order to entertain a request for equitable relief, a district court must have 3 equitable jurisdiction, which can only exist under federal common law if the plaintiff 4 has no adequate legal remedy.” Guzman v. Polaris Indus. Inc., 49 F.4th 1308, 1313 5 (9th Cir. 2022) (citations omitted); see also Guar. Tr. Co. of N.Y. v. York, 326 U.S. 99, 6 105 (1945) (equitable relief in federal courts is “subject to restrictions: the suit must 7 be within the traditional scope of equity as historically evolved in the English Court of 8 Chancery[;] a plain, adequate and complete remedy at law must be wanting[;] explicit 9 Congressional curtailment of equity powers must be respected[; and] the constitutional 10 right to trial by jury cannot be evaded[.]”) (citations omitted). “Even when a court has 11 subject matter jurisdiction, there remains the question of equitable jurisdiction before 12 the district court properly can reach the merits.” Guzman, 49 F.4th at 1314 13 (capitalization modified) (internal quotation marks omitted) (citing Schlesinger v. 14 Councilman, 420 U.S. 738, 754 (1975)). “That a State may authorize its courts to 15 give equitable relief unhampered by the restriction that an adequate remedy at law be 16 unavailable cannot remove that fetter from the federal courts.” Sonner v. Premier 17 Nutrition Corp., 971 F.3d 834, 839–44 (9th Cir. 2020) (cleaned up). 18 The court has reviewed the Complaint and is presently unable to conclude it has 19 equitable jurisdiction. Dkt. 1, Ex. 1 (“Compl.”). The only claims asserted are brought 20 under the California Unfair Competition Law (the “UCL”), Cal. Bus. & Prof. Code 21 § 17200, et seq., and remedies available under the UCL are equitable in nature, Cel- 22 Tech Commc’ns, Inc. v. Los Angeles Cellular Tel. Co., 20 Cal. 4th 163, 179 (1999); 23 Hodge v. Superior Ct., 145 Cal. App. 4th 278, 284 (2006) (the UCL “provides only 24 for equitable remedies”). A remedy at law, however, appears adequate to address the 25 alleged harm. See Compl. ¶¶ 1, 8–9 (defendant allegedly advertised falsely its 26 vitamins were free of artificial flavors). 27 Accordingly, the parties are ORDERED to show cause, in writing within 28 fourteen (14) days from the date of this Order, why this action should not be remanded 1 | for lack of equitable jurisdiction because an adequate remedy at law exists. See 2 | Guthrie v. Transamerica Life Ins. Co., 561 F. Supp. 3d 869, 871-80 (N.D. Cal. 2021) 3 | (remanding action for lack of equitable jurisdiction where plaintiff sought only 4 | restitution under the UCL). Responses shall be limited to 4,200 words. Failure to 5 | respond timely to this Order may result in remand of the action without further notice. 6 7 IT IS SO ORDERED. 8 9 | Dated: March 11, 2025 10 FERNANDO L. AENLLE-ROCHA United States District Judge

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