Brook Mancinelli v. Marriott International, Inc.

CourtDistrict Court, N.D. California
DecidedApril 15, 2026
Docket4:25-cv-08246
StatusUnknown

This text of Brook Mancinelli v. Marriott International, Inc. (Brook Mancinelli v. Marriott International, 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
Brook Mancinelli v. Marriott International, Inc., (N.D. Cal. 2026).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 BROOK MANCINELLI, Case No. 25-cv-08246-JST

8 Plaintiff, ORDER DENYING MOTION TO 9 v. REMAND

10 MARRIOTT INTERNATIONAL, INC., Re: ECF No. 13 Defendant. 11

12 13 Before the Court is Plaintiff Brook Mancinelli’s motion to remand. ECF No. 13. The 14 Court will deny the motion. 15 I. BACKGROUND 16 Mancinelli, individually and on behalf of a putative class, brings this action against 17 Defendant Marriott International, Inc. (“Marriott”) for allegedly misleading pricing practices. 18 ECF No. 1-2 ¶ 1. He alleges that California residents who used their Marriott Bonvoy points to 19 book hotel accommodations are initially shown one total hotel cost that does not include a “resort” 20 or “destination” fee at the beginning of the reservation process. Id. ¶ 4. Only at the end of the 21 booking process, “after a consumer has invested time, effort and cognitive energy in the buying 22 process,” is the customer shown the mandatory resort fee, a practice Mancinelli calls “drip 23 pricing.” Id. ¶ 4–5. “Marriot thus creates a misleading impression that loyalty members can 24 complete their reservation using points alone, without paying additional charges.” Id. ¶ 7. 25 Mancinelli alleges that this practice violates California’s Honest Pricing Law. Id. ¶¶ 6, 8, 38. He 26 asserts claims for violation of the California Consumer Legal Remedies Act (“CLRA”), Cal. Civil 27 Code §§ 1750 et seq.; and California’s Unfair Competition Law, Cal. Bus. & Prof. Code §§ 17200 1 Mancinelli filed his complaint in Contra Costa County Superior Court on August 25, 2025. 2 Marriott removed the case to this Court on September 26, 2025. ECF No. 1. Mancinelli moved to 3 remand the case on October 9, 2025. ECF No. 13. Marriott filed an opposition on October 29, 4 2025, attaching certain declarations, ECF Nos. 20, 20-3, which Mancinelli moved to exclude, ECF 5 No. 26 at 10. After further motion practice, Marriott was permitted to file two additional 6 declarations, and Mancinelli was permitted to file a surreply, ECF No. 37, which he did on March 7 2, 2026, ECF No. 40. 8 II. LEGAL STANDARD 9 Under 28 U.S.C. § 1446, a defendant may remove a civil action from state to federal court 10 if the federal court has subject matter jurisdiction over the case. The Ninth Circuit “strictly 11 construe[s] the removal statute against removal jurisdiction,” and “[f]ederal jurisdiction must be 12 rejected if there is any doubt as to the right of removal in the first instance.” Gaus v. Miles, Inc., 13 980 F.2d 564, 566 (9th Cir.1992); Luther v. Countrywide Home Loans Servicing LP, 533 F.3d 14 1031, 1034 (9th Cir. 2008); see 28 U.S.C. § 1441. “The ‘strong presumption’ against removal 15 jurisdiction means that the defendant always has the burden of establishing that removal is 16 proper.” Gaus, 980 F.2d at 566 (citing Nishimoto v. Federman–Bachrach & Assocs., 903 F.2d 17 709, 712 n.3 (9th Cir. 1990); Emrich v. Touche Ross & Co., 846 F.2d 1190, 1195 (9th Cir. 1988)). 18 The Class Action Fairness Act (“CAFA”), 28 U.S.C. § 1332(d), “gives federal courts 19 jurisdiction over certain class actions, defined in § 1332(d)(1), if the class has more than 100 20 members, the parties are minimally diverse, and the amount in controversy exceeds $5 21 million.” Dart Cherokee Basin Operating Co., LLC v. Owens, 574 U.S. 81 at 84–85 (2014) (citing 22 § 1332(d)(2), (5)(B)). “The amount in controversy is simply an estimate of the total amount in 23 dispute, not a prospective assessment of defendant’s liability.” Arias v. Residence Inn by 24 Marriott, 936 F.3d 920, 927 (9th Cir. 2019) (citation modified). “In that sense, the amount in 25 controversy reflects the maximum recovery the plaintiff could reasonably recover.” Arias, 936 26 F.3d at 927; see also Chavez v. JPMorgan Chase & Co., 888 F.3d 413, 417 (9th Cir. 2018) 27 (holding that the that the amount in controversy includes all amounts “‘at stake’ in the litigation, 1 In a CAFA case, “a defendant’s notice of removal need include only a plausible allegation 2 that the amount in controversy exceeds the jurisdictional threshold.” Dart Cherokee, 574 U.S. at 3 89. If, however, “a defendant’s assertion of the amount in controversy is challenged,” then “both 4 sides submit proof and the court decides, by a preponderance of the evidence, whether the amount- 5 in-controversy requirement has been satisfied.” Ibarra v. Manheim Invs., Inc., 775 F.3d 1193, 6 1195 (9th Cir. 2015) (quoting Dart Cherokee, 574 U.S. at 82). The parties may rely on “evidence 7 outside the complaint, including affidavits or declarations, or other ‘summary-judgment-type 8 evidence relevant to the amount in controversy at the time of removal.’” Id. at 1197 (quoting 9 Singer v. State Farm Mut. Auto. Ins. Co., 116 F.3d 373, 377 (9th Cir. 1997)). CAFA thus requires 10 a court to determine the amount in controversy based on “consideration of real evidence and the 11 reality of what is at stake in the litigation, using reasonable assumptions underlying the 12 defendant’s theory of damages exposure.” Id. at 1198. Accordingly, “when the defendant relies 13 on a chain of reasoning that includes assumptions to satisfy its burden of proof, the chain of 14 reasoning and its underlying assumptions must be reasonable ones.” LaCross v. Knight Transp. 15 Inc., 775 F.3d 1200, 1202 (9th Cir. 2015). “Under the preponderance of the evidence standard, if 16 the evidence submitted by both sides is balanced, in equipoise, the scales tip against federal[] court 17 jurisdiction.” Ibarra, 775 F.3d at 1199. 18 III. DISCUSSION 19 Mancinelli moves to remand this action to state court, arguing that Marriott has failed to 20 establish federal jurisdiction under either 28 U.S.C. §§1332(a) or 1332(d). Mancinelli does not 21 dispute that the proposed class has more than 100 members and that the parties are minimally 22 diverse. Dart Cherokee, 574 U.S. at 84. He argues, however, that Marriott has not shown that the 23 amount in controversy exceeds $5,000,000. ECF No. 13 at 6. 24 In estimating the amount in controversy, the Ninth Circuit directs the parties to include the 25 amount of damages at issue, as well as attorney’s fees through the date of judgment if the 26 underlying statute authorizes an award of attorney’s fees. Galt G/S v. JSS Scandinavia, 142 F.3d 27 1150, 1155-56 (9th Cir. 1998); Chavez v. JPMorgan Chase & Co., 888 F.3d 413 (9th Cir. 2018). 1 controversy exceeds $5,000,000 is “offered without any data, periodization, transaction counts, fee 2 amounts, or calculations.” ECF No. 13 at 6. Mancinelli misunderstands the burden on a removing 3 defendant. A notice of removal need only “contain[] a short and plain statement of the grounds for 4 removal,” 28 U.S.C.

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Bluebook (online)
Brook Mancinelli v. Marriott International, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/brook-mancinelli-v-marriott-international-inc-cand-2026.