Angela Standlee v. Abbott Laboratories

District Court, C.D. California·Decided May 5, 2025·No. 2:24-cv-09586·Unknown

Opinion

JS-6 ANGELA STANDLEE, Case No. 2:24-cv-09586-FLA (MAAx)

Plaintiff, ORDER GRANTING PLAINTIFF’S v. MOTION TO REMAND AND DENYING REQUEST FOR ATTORNEY’S FEES [DKT. 20] ABBOTT LABORATORIES, et al., Defendants.

Before the court is Plaintiff Angela Standlee’s (“Plaintiff”) Motion for Remand to the Los Angeles County Superior Court (“Motion”). Dkt. 20 (“Mot.”); Dkt. 20-1 (“Mot. Br.”). Defendants Abbott Laboratories (“Abbott”) and St. Jude Medical S.C., Inc. (“SJMSC”) (together, “Corporate Defendants”) oppose the Motion. Dkt. 22 (“Opp’n”). Defendant Tony Li (“Li”) did not respond to the Motion. On January 8, 2025, the court found the Motion appropriate for resolution without oral argument and vacated the hearing set for January 10, 2025. Dkt. 29; see Fed. R. Civ. P. 78(b); Local Rule 7-15. For the reasons stated herein, the court GRANTS the Motion and REMANDS this action to the Los Angeles County Superior Court. This action arises from the purported retaliation, discriminatory treatment, and failure to accommodate that Plaintiff was subjected to during her employment as a technical services specialist for Corporate Defendants. Dkt. 4-1 at 3–25 (“Compl.”).1 On December 13, 2023, Plaintiff filed the Complaint in the Los Angeles County Superior Court, asserting ten causes of action against Abbott, SJMSC, and Li for: (1) retaliation; (2) discrimination in violation of the California Fair Employment and Housing Act (“FEHA”); (3) failure to accommodate in violation of FEHA; (4) failure to engage in a timely and good-faith interactive process; (5) harassment in violation of FEHA; (6) retaliation in violation of FEHA; (7) failure to prevent discrimination, harassment, retaliation; (8) wrongful discharge in violation of public policy; (9) defamation; and (10) intentional infliction of emotional distress. Id. ¶¶ 35–116. Plaintiff asserts the fifth, ninth, and tenth causes of action against all Defendants, and the remaining causes of action against the Corporate Defendants only.

1 The court cites documents by the page numbers added by the court’s CM/ECF system, rather than any page numbers that appear within the documents natively. On November 5, 2024, Corporate Defendants removed this action to this court alleging diversity jurisdiction. Dkt. 1; see 28 U.S.C. § 1332(a)(1). In the instant Motion, Plaintiff contends complete diversity does not exist because Plaintiff and Li are both California citizens. Mot. Br. at 5, 7. Corporate Defendants, in opposition, argue Li is a “sham defendant,” who was named solely to defeat subject matter jurisdiction. Opp’n at 11. I. Legal Standard Federal courts are courts of “limited jurisdiction,” possessing “only that power authorized by the Constitution and statute[.]” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994); U.S. Const. art. III, § 2, cl. 1. “It is to be presumed that a cause lies outside [of federal courts’] limited jurisdiction, and the burden of establishing the contrary rests upon the party asserting jurisdiction.” Kokkonen, 511 U.S. at 377 (citations omitted); Sopcak v. N. Mountain Helicopter Serv., 52 F.3d 817, 818 (9th Cir. 1995). A challenge to subject matter jurisdiction “can be either facial, confining the inquiry to allegations in the complaint, or factual, permitting the court to look beyond the complaint.” Savage v. Glendale Union High Sch., 343 F.3d 1036, 1039 n. 2 (9th Cir. 2003). Therefore, the court is not restricted to the face of the pleadings and may review evidence, such as declarations and testimony, to resolve any factual disputes concerning the existence of jurisdiction. See McCarthy v. United States, 850 F.2d 558, 560 (9th Cir. 1988). Federal courts have jurisdiction where each plaintiff’s citizenship is diverse from each defendant’s citizenship and the amount in controversy exceeds $75,000, exclusive of interest and costs. 28 U.S.C. § 1332(a)(1). Diversity jurisdiction requires “complete diversity, meaning that each plaintiff must be of a different citizenship from each defendant.” Grancare, LLC v. Thrower, 889 F.3d 543, 548 (9th Cir. 2018) (citation omitted). “In determining whether there is complete diversity, district courts may disregard the citizenship of a non-diverse defendant who has been fraudulently joined.” Id. (citation omitted). “A defendant invoking federal court diversity jurisdiction on the basis of fraudulent joinder bears a ‘heavy burden’ since there is a general presumption against finding fraudulent joinder.” Id. (cleaned up); see also Hamilton Materials, Inc. v. Dow Chem. Corp., 494 F.3d 1203, 1206 (9th Cir. 2007) (“Fraudulent joinder must be proven by clear and convincing evidence.”). “There are two ways to establish fraudulent joinder: (1) actual fraud in the pleading of jurisdictional facts, or (2) inability of the plaintiff to establish a cause of action against the non-diverse party in state court.”2 Grancare, 889 F.3d at 548 (internal quotation marks and citations omitted). “Fraudulent joinder is established the second way if a defendant shows that an individual joined in the action cannot be liable on any theory.” Id. (cleaned up). “But if there is a possibility that a state court would find that the complaint states a cause of action against any of the resident defendants, the federal court must find that the joinder was proper and remand the case to the state court.” Id. (cleaned up) (emphasis in original). II. Analysis Defendants argue Plaintiff cannot state a claim for hostile work environment under FEHA against Li because “[b]ased on her deposition testimony, she cannot prevail on a harassment claim against Li based on age, sex/gender, or disability.” Opp’n at 22. The court disagrees. A. Hostile Work Environment Under FEHA Under FEHA, an employee who harasses another employee may be held personally liable. Lewis v. City of Benicia, 224 Cal. App. 4th 1519, 1524 (2014) (citing Cal. Gov’t Code § 12940(j)(3)). To establish a prima facie case of a hostile 2 Here, Corporate Defendants seek to establish fraudulent joinder in the second way, by arguing Plaintiff cannot establish a cause of action against Li in California state court. See Opp’n at 13–26. work environment, a plaintiff must show: “(1) she is a member of a protected class; (2) she was subjected to unwelcome harassment; (3) the harassment was based on her protected status; (4) the harassment unreasonably interfered with her work performance by creating an intimidating, hostile, or offensive work environment; and (5) defendants are liable for the harassment.” Ortiz v. Dameron Hosp. Ass’n, 37 Cal. App. 5th 568, 581 (2019). To show “unreasonable interference,” the plaintiff need not prove that his or her tangible productivity has declined as a result of the harassment. It suffices to prove that a reasonable person subjected to the discriminatory conduct would find, as the plaintiff did, that the harassment so altered working conditions as to make it more difficult to do the job. Cal

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