Brink Biologics Inc. v. Sanofi S.A.

CourtDistrict Court, C.D. California
DecidedApril 19, 2021
Docket2:21-cv-02171
StatusUnknown

This text of Brink Biologics Inc. v. Sanofi S.A. (Brink Biologics Inc. v. Sanofi S.A.) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brink Biologics Inc. v. Sanofi S.A., (C.D. Cal. 2021).

Opinion

CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES - GENERAL Case No. CV 21-2171 FMO (Ex) Date April 19, 2021 Title Brink Biologics, Inc. v. Sanofi S.A., et al.

Present: The Honorable Fernando M. Olguin, United States District Judge Vanessa Figueroa None None Deputy Clerk Court Reporter / Recorder Tape No. Attorney Present for Plaintiff(s): Attorney Present for Defendant(s): None Present None Present Proceedings: (In Chambers) Order Remanding Action On January 19, 2021, plaintiff Brink Biologics, Inc. (“plaintiff”) filed a Complaint in the Los Angeles County Superior Court against Sanofi S.A., Sanofi-Aventis US LLC (“Sanofi US”), and Sanofi-Aventis Recherche & Developpement S.A. (collectively, “defendants”), asserting claims for breach of contract, declaratory relief, restitution for unjust enrichment, and violations of California’s Unfair Competition Law (“UCL”), Cal. Bus. & Prof. Code §§ 17200, et seq. (See Dkt. 1, Notice of Removal (“NOR”) at 1); (Dkt. 1-2, Exh. 1, Complaint at ¶¶ 52-85). On March 10, 2021, Sanofi US removed the action on diversity jurisdiction grounds pursuant to 28 U.S.C. §§ 1332 and 1441. (See Dkt. 1, NOR at 2). Having reviewed the pleadings, the court hereby remands this action to state court for lack of subject matter jurisdiction. See 28 U.S.C. § 1447(c). In general, “any civil action brought in a State court of which the district courts of the United States have original jurisdiction, may be removed by the defendant or the defendants, to the district court[.]” 28 U.S.C. § 1441(a). A removing defendant bears the burden of establishing that removal is proper. See Gaus v. Miles, Inc., 980 F.2d 564, 566 (9th Cir. 1992) (per curiam) (“The strong presumption against removal jurisdiction means that the defendant always has the burden of establishing that removal is proper.”) (internal quotation marks omitted); Abrego Abrego v. The Dow Chem. Co., 443 F.3d 676, 684 (9th Cir. 2006) (per curiam) (noting the “longstanding, near- canonical rule that the burden on removal rests with the removing defendant”). If there is any doubt regarding the existence of subject matter jurisdiction, the court must resolve those doubts in favor of remanding the action to state court.1 See Gaus, 980 F.2d at 566 (“Federal jurisdiction must be rejected if there is any doubt as to the right of removal in the first instance.”). Indeed, “[i]f at any time before final judgment it appears that the district court lacks subject matter jurisdiction, the case shall be remanded.” 28 U.S.C. § 1447(c); see Kelton Arms Condo. Owners Ass’n, Inc. v. Homestead Ins. Co., 346 F.3d 1190, 1192 (9th Cir. 2003) (“Subject matter jurisdiction may not 1 An “antiremoval presumption” does not exist in cases removed pursuant to the Class CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES - GENERAL Case No. CV 21-2171 FMO (Ex) Date April 19, 2021 Title Brink Biologics, Inc. v. Sanofi S.A., et al. be waived, and, indeed, we have held that the district court must remand if it lacks jurisdiction.”); Washington v. United Parcel Serv., Inc., 2009 WL 1519894, *1 (C.D. Cal. 2009) (a district court may remand an action where the court finds that it lacks subject matter jurisdiction “either by motion or sua sponte”). The court’s review of the NOR and the attached state court Complaint makes clear that this court does not have subject matter jurisdiction over the instant matter. In other words, plaintiff could not have originally brought this action in federal court, as plaintiff does not competently allege facts supplying diversity jurisdiction.2 Therefore, removal was improper. See 28 U.S.C. § 1441(a); Caterpillar, Inc. v. Williams, 482 U.S. 386, 392, 107 S.Ct. 2425, 2429 (1987) (“Only state-court actions that originally could have been filed in federal court may be removed to federal court by the defendant.”). When federal subject matter jurisdiction is predicated on diversity of citizenship, see 28 U.S.C. § 1332(a), complete diversity must exist between the opposing parties, see Caterpillar Inc. v. Lewis, 519 U.S. 61, 68, 117 S.Ct. 467, 472 (1996) (stating that the diversity jurisdiction statute “applies only to cases in which the citizenship of each plaintiff is diverse from the citizenship of each defendant”), and the amount in controversy must exceed $75,000. See 28 U.S.C. § 1332(a).3 Here, there is no basis for diversity jurisdiction because complete diversity does not exist between the opposing parties. Plaintiff appears to be a citizen of California and Delaware, (see Dkt. 1, NOR at 4), and Sanofi US is a citizen of Delaware.4 (See id.). However, “[i]n determining whether there is complete diversity, district courts may disregard the citizenship of a non-diverse defendant who has been fraudulently joined.” Grancare, LLC v. Thrower ex rel. Mills, 889 F.3d 543, 548 (9th Cir. 2018); see Allen v. Boeing Co., 784 F.3d 625, 634 (9th Cir. 2015) (“[J]oinder is fraudulent when a plaintiff’s failure to state a cause of action against the [non-diverse] defendant is obvious according to the applicable state law.”). A defendant must show by “clear and convincing evidence” that the plaintiff does not have a colorable claim against the alleged sham defendant. 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.”); Mireles v. Wells Fargo Bank, N.A., 2 Sanofi US seeks only to invoke the court’s diversity jurisdiction. (See, generally, Dkt. 1, NOR). 3 In relevant part, 28 U.S.C. § 1332(a) provides that a district court has diversity jurisdiction “where the matter in controversy exceeds the sum or value of $75,000, . . . and is between . . . citizens of different States” or “citizens of a State and citizens or subjects of a foreign state[.]” 28 U.S.C. §§ 1332(a)(1)-(2). CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES - GENERAL Case No. CV 21-2171 FMO (Ex) Date April 19, 2021 Title Brink Biologics, Inc. v. Sanofi S.A., et al. 845 F.Supp.2d 1034, 1063 (C.D. Cal. 2012) (“Demonstrating fraudulent joinder” requires showing that “after all disputed questions of fact and all ambiguities . . .

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Caterpillar Inc. v. Williams
482 U.S. 386 (Supreme Court, 1987)
Caterpillar Inc. v. Lewis
519 U.S. 61 (Supreme Court, 1996)
Hamilton Materials, Inc. v. Dow Chemical Corp.
494 F.3d 1203 (Ninth Circuit, 2007)
Padilla v. AT & T CORP.
697 F. Supp. 2d 1156 (C.D. California, 2009)
Rutherford Holdings, LLC v. Plaza Del Rey
223 Cal. App. 4th 221 (California Court of Appeal, 2014)
Skye Astiana v. the Hain Celestial Group
783 F.3d 753 (Ninth Circuit, 2015)
Jocelyn Allen v. the Boeing Company
784 F.3d 625 (Ninth Circuit, 2015)
Grancare v. Ruth Thrower
889 F.3d 543 (Ninth Circuit, 2018)
Mireles v. Wells Fargo Bank, N.A.
845 F. Supp. 2d 1034 (C.D. California, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Brink Biologics Inc. v. Sanofi S.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/brink-biologics-inc-v-sanofi-sa-cacd-2021.