Brugman v. State Farm Mutual Automobile Insurance Company

CourtDistrict Court, D. Nevada
DecidedJanuary 16, 2025
Docket2:24-cv-00888
StatusUnknown

This text of Brugman v. State Farm Mutual Automobile Insurance Company (Brugman v. State Farm Mutual Automobile Insurance Company) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brugman v. State Farm Mutual Automobile Insurance Company, (D. Nev. 2025).

Opinion

1 2 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 3 4 Jacquelynn Brugman, Case No. 2:24-cv-00888-CDS-BNW

5 Plaintiff Order Granting Plaintiff’s Motion to Remand and Denying Plaintiff’s Request for 6 v. Attorney’s Fees

7 State Farm Mutual Automobile Insurance Company, et al., [ECF No. 8] 8 Defendants 9 10 Defendant State Farm Mutual Automobile Insurance Company removed this case from 11 Eighth Judicial District Court of Nevada. Pet. for removal, ECF No. 1. Plaintiff Jacquelynn 12 Brugman is seeking to remand the case back to state court, arguing both that the parties are not 13 diverse and that the amount in controversy does not exceed $75,000. Mot. to remand, ECF No. 8 14 at 3. In response, State Farm admits that plaintiff, and defendant Rogers Mastrangelo Carvhalho 15 & Mitchell Ltd. (“RMCM”)—a law firm—are both residents of Nevada but argues that it has 16 been fraudulently joined. Response, ECF No. 11 at 3. State Farm also argues that the amount in 17 controversy exceeds $75,000. Id. The motion is fully briefed. See Reply, ECF No. 12. Because State 18 Farm has not demonstrated that the amount in controversy exceeds $75,000, the motion to 19 remand is granted. 20 I. Background 21 Brugman filed suit in Eighth Judicial District Court of Clark County, Nevada seeking 22 recovery from her insurer, State Farm, and RMCM, who she has designated as agents of State 23 Farm. ECF No. 1 at 8–9. After being hit by an at-fault driver, Brugman suffered injuries to herself 24 and her vehicle. Id. at 9. She alleges that she filed a claim with State Farm, which evaluated her 25 damages at $0.00. Id. Brugman now brings breach of contract and statutory unfair claims 26 practice claims against State Farm and tortious and contractual breach of the implied covenant 1 of good faith and fair dealing claims against all defendants. Id. at 10–15. She raises a declaratory 2 relief claim against State Farm seeking a judicial determination of the rights and benefits under 3 the insurance contract. Id. at 15–16. In her prayer for relief, Brugman requests “[g]eneral and 4 emotional damages, statutory damages, medical expenses, and other special damages in the 5 amount in excess of $15,000.00” as well as interest under NRS 99.040, punitive damages, 6 reasonable attorney’s fees and costs, and prejudgment and post-judgment interest. Id. at 16–17. 7 State Farm removed the case to this court on May 13, 2024. 8 II. Legal standard 9 “Federal courts are courts of limited jurisdiction.” Kokkonen v. Guardian Life Ins. Co. of 10 America, 511 U.S. 375, 377 (1994). When a case is filed in state court between parties who are 11 citizens of different states, and the amount in controversy is at least $75,000, the defendant may 12 remove the case to federal court. 28 U.S.C. §§ 1332, 1441, 1446. But there is a strong presumption 13 against removal jurisdiction, and “federal jurisdiction must be rejected if there is any doubt as to 14 the right of removal in the first instance.” Gaus v. Miles, 980 F.2d 564, 566 (9th Cir. 1992). The 15 defendant always has the burden of establishing that removal is proper. Id. 16 “Diversity removal requires complete diversity, meaning that each plaintiff must be of a 17 different citizenship from each defendant.” Grancare, LLC v. Thrower by and through Mills, 889 F.3d 18 543, 548 (9th Cir. 2018) (citing Caterpillar Inc. v. Lewis, 519 U.S. 61, 68 (1996)). But “[i]n 19 determining whether there is complete diversity, district courts may disregard the citizenship of 20 a non-diverse defendant who has been fraudulently joined.” Id. (citing Chesapeake & O. R. Co. v. 21 Cockrell, 232 U.S. 146, 152 (1914)). 22 In determining the amount in controversy, courts first look to the complaint. Generally, 23 “the sum claimed by the plaintiff controls if the claim is apparently made in good faith.” St. Paul 24 Mercury Indem. Co. v. Red Cab Co., 303 U.S. 283, 288 (1938) (footnote omitted). The $75,000 25 threshold is satisfied if the plaintiff claims a sum greater than the jurisdictional requirement. See 26 id. at 288–89; Pachinger v. MGM Grand Hotel-Las Vegas, Inc., 802 F.2d 362, 363 (9th Cir. 1986). 1 However, like in this case, when removal jurisdiction is challenged by a plaintiff, evidence 2 establishing the amount in controversy is required. Dart Cherokee Basin Operating Co., LLC v. Owens, 3 574 U.S. 81, 88 (2014). “In such a case, both sides submit proof and the court decides, by a 4 preponderance of the evidence, whether the amount-in-controversy requirement has been 5 satisfied.” Id. (citing 28 U.S.C. § 1446(c)(2)(B)) (emphasis added). As to the kind of evidence 6 that may be considered, the Ninth Circuit has adopted the “practice of considering facts 7 presented in the removal petition as well as any ‘summary-judgment-type evidence relevant to 8 the amount in controversy at the time of removal.’” Matheson v. Progressive Specialty Ins. Co., 319 F.3d 9 1089, 1090 (9th Cir. 2003) (quoting Singer v. State Farm Mut. Auto. Ins. Co., 116 F.3d 373, 377 (9th Cir. 10 1997)). Conclusory allegations are insufficient. Id. at 1090 (citation omitted). It is ultimately the 11 defendant’s burden to prove that the amount in controversy exceeds $75,000 “when the plaintiff 12 does not plead a specific amount in controversy.” Rodriguez v. AT & T Mobility Servs. LLC, 728 F.3d 13 975, 981 (9th Cir. 2013). 14 III. Discussion 15 Brugman asserts that this action should be remanded to state court because the 16 defendant cannot meet its burden establishing that the amount in controversy in this action 17 exceeds $75,000. ECF No. 8 at 3. In her complaint, Brugman seeks “General and emotional 18 damages, statutory damages, medical expenses, and other special damages in the amount in 19 excess of $15,000.00” as well as interest under NRS 99.040, punitive damages, reasonable 20 attorney’s fees and costs, and prejudgment and post-judgment interest. ECF No. 1 at 16–17. State 21 Farm insists that the claimed amount exceeds $75,000 because Brugman’s underinsured motor 22 vehicle (UIM) policy claim alleges that she has incurred medical specials of $28,254.18, “with a 23 recommendation from Dr. Ryan West for a course of future treatment with an estimated cost of 24 $395,600.” Statement concerning removal, ECF No. 7 at 3. State Farm states that Brugman has 25 already been paid $100,000 from her policy, so her claimed damages are, at a minimum $125,000. 26 Id. It also cites a number of bad faith verdicts in Nevada as proof of the amount in controversy. 1 Id. at 4; see also ECF No. 11 at 20. In her motion to remand, Brugman admits that her medical 2 specials are “less than $29,000.” ECF No. 8 at 13. 3 Regarding defendant’s assertions about the future medical expenses, State Farm makes 4 nothing but bald, conclusory assertions.

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Related

Chesapeake & Ohio Railway Co. v. Cockrell
232 U.S. 146 (Supreme Court, 1914)
Saint Paul Mercury Indemnity Co. v. Red Cab Co.
303 U.S. 283 (Supreme Court, 1938)
Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Caterpillar Inc. v. Lewis
519 U.S. 61 (Supreme Court, 1996)
Eberhart v. United States
546 U.S. 12 (Supreme Court, 2005)
United States v. Roscoe B. Sargent
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Surber v. Reliance National Indemnity Co.
110 F. Supp. 2d 1227 (N.D. California, 2000)
United States v. Lopez-Pastrana
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Gibson v. Chrysler Corp.
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Bongiovi v. Sullivan
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Bakken v. State Farm Insurance
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Bluebook (online)
Brugman v. State Farm Mutual Automobile Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brugman-v-state-farm-mutual-automobile-insurance-company-nvd-2025.