Carroll v. Ameri-Force Craft Services, Inc..

CourtDistrict Court, S.D. California
DecidedSeptember 11, 2025
Docket3:24-cv-01443
StatusUnknown

This text of Carroll v. Ameri-Force Craft Services, Inc.. (Carroll v. Ameri-Force Craft Services, Inc..) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carroll v. Ameri-Force Craft Services, Inc.., (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 MARION J. CARROLL, an individual Case No.: 24-cv-1443-RSH-DTF and on behalf of all others similarly 12 situated, ORDER DENYING PLAINTIFF’S 13 MOTION TO REMAND Plaintiff,

14 v. [ECF No. 22] 15

16 AMERI-FORCE CRAFT SERVICES, 17 INC., et. al., 18 Defendant. 19 20 Pending before the Court is Plaintiff’s motion to remand the action to state court. 21 ECF No. 22. The motion is fully briefed. ECF Nos. 24-26. As set forth below, the Court 22 denies the motion. 23 I. BACKGROUND 24 On June 6, 2024, plaintiff Marion J. Carroll filed this wage and hour putative class 25 action in the California Superior Court for the County of San Diego against defendants 26 Ameri-Force Craft Services, Inc. (“Ameri-Force”); National Steel and Shipbuilding Co. 27 (“NASSCO”); and Misael Vidama. ECF No. 1-2. The Complaint alleges that Plaintiff 28 worked for Defendants as a non-exempt employee from August 2023 through May 2024. 1 Id. ¶ 2. She seeks to represent a class of “all current and former non-exempt employees of 2 Defendants within the State of California at any time commencing four (4) years preceding 3 the filing of Plaintiff’s complaint up until the time that notice of the class action is provided 4 to the class.” Id. ¶ 28. The Complaint brings claims for: (1) failure to pay overtime; (2) 5 failure to pay minimum wages; (3) failure to provide meal periods; (4) failure to provide 6 rest periods; (5) failure to pay wages due upon separation; (6) failure to provide accurate 7 wage statements; (7) failure to timely pay wages during employment; (8) violation of 8 California Labor Code § 2802, requiring reimbursement for certain employee expenses; 9 (9) violation of California Labor Code § 227.3, requirement payment of vested vacation 10 time upon termination; and (10) failure to provide paid sick leave, in violation of California 11 Business & Professions Code § 17200 and the Healthy Workplace Healthy Families Act 12 of 2014, codified at California Labor Code § 245 et seq. 13 On August 14, 2024, Ameri-Force removed the action to this Court pursuant to the 14 removal provision in the Class Action Fairness Act (“CAFA”), 28 U.S.C. § 1332(d). ECF 15 No. 1. 16 On September 10, 2024, pursuant to a joint motion by the Parties, the Court stayed 17 the action to allow the Parties to pursue mediation. ECF No. 11. After the Parties advised 18 that they were unable to reach a settlement, the Court lifted the stay on May 27, 2025. ECF 19 No. 20. 20 On July 10, 2025, Ameri-Force filed its motion to remand. ECF No. 22. NASSCO 21 has joined in the motion. ECF No. 25. 22 II. LEGAL STANDARD 23 The Class Action Fairness Act “provides the federal district courts with ‘original 24 jurisdiction’ to hear a ‘class action’ if the class has more than 100 members, the parties are 25 minimally diverse, and the “matter in controversy exceeds the sum or value of $5,000,000.” 26 Standard Fire Ins. Co. v. Knowles, 568 U.S. 588, 592 (2013) (quoting 28 U.S.C. §§ 27 1332(d)(2), (5)(B)). “The burden of establishing removal jurisdiction, even in CAFA cases, 28 lies with the defendant seeking removal.” Wash. State v. Chimei Innolux Corp., 659 F.3d 1 842, 847 (9th Cir. 2011). “[N]o antiremoval presumption attends cases invoking CAFA.” 2 Dart Cherokee Basin Operating Co., LLC v. Owens, 574 U.S. 81, 83 (2014). 3 III. ANALYSIS 4 A. Amount in Controversy 5 1. Generally 6 Plaintiff first argues that Defendants have failed to satisfy the amount-in-controversy 7 requirement under CAFA. ECF No. 22 at 8. To satisfy that requirement, “a removing party 8 must initially file a notice of removal that includes ‘a plausible allegation that the amount 9 in controversy exceeds the jurisdictional threshold.’” LaCross v. Knight Transp. Inc., 775 10 F.3d 1200, 1202 (9th Cir. 2015) (quoting Dart Cherokee, 574 U.S. at 89). “[T]he defendant 11 seeking removal bears the burden of proof to establish by a preponderance of the evidence 12 that the amount-in-controversy requirement is satisfied.” Id. 13 “Generally, the sum claimed by the plaintiff controls if the claim is apparently made 14 in good faith.” Lewis, 627 F.3d at 399 (internal quotation marks omitted). “Similarly, when 15 a defendant seeks federal-court adjudication, the defendant’s amount-in-controversy 16 allegation should be accepted when not contested by the plaintiff or questioned by the 17 court.” Dart Cherokee, 574 U.S. at 87. However, “if the plaintiff contests the defendant’s 18 allegation ... both sides submit proof and the court decides, by a preponderance of the 19 evidence, whether the amount-in-controversy requirement has been satisfied.” Id. at 88. 20 “Because the Court evaluates a challenged amount-in-controversy estimate under 21 the preponderance of the evidence standard, the defendant need only establish ‘that the 22 potential damage could exceed the jurisdictional amount.’” Campbell, 2025 WL 720188, 23 at *3 (quoting Rea v. Michaels Stores Inc., 742 F.3d 1234, 1239 (9th Cir. 2014)). “The 24 amount in controversy is simply an estimate of the total amount in dispute, not a 25 prospective assessment of defendant’s liability.” Lewis v. Verizon Communs., Inc., 627 26 F.3d 395, 400 (9th Cir. 2010). 27 “While the defendant’s amount-in-controversy estimate must be grounded in the 28 plaintiff’s complaint, the parties’ additional evidence may include ‘affidavits or 1 declarations, or other summary-judgment-type evidence relevant to the amount-in- 2 controversy at the time of removal.’” Campbell v. SkyWest Airlines, Inc., No. 3:24-CV- 3 2141 TWR (SBC), 2025 WL 720188, at *3 (S.D. Cal. Mar. 6, 2025) (quoting Ibarra v. 4 Manheim Invs., Inc., 775 F.3d 1193, 1197 (9th Cir. 2015)). Although the removing party 5 may rely “on a chain of reasoning that includes assumptions to satisfy its burden to prove 6 by a preponderance of the evidence that the amount in controversy exceeds $5 million,” 7 the “reasoning and underlying assumptions” must be “reasonable.” Jauregui v. Roadrunner 8 Transp. Servs., 28 F.4th 989, 993 (9th Cir. 2022) (internal quotation marks omitted). 9 “[I]n most wage and hour class actions, CAFA amount-in-controversy estimates are 10 premised on three variables: (1) the total number of possible violations; (2) the frequency 11 at which violations might have occurred; and (3) the potential cost associated with each 12 hypothetical violation.” Salatino v. Am. Airlines, Inc., 719 F. Supp. 3d 1094, 1100 (S.D. 13 Cal. 2024). “Once each of these variables is assigned a value, the interplay between them 14 is relatively simple in most cases; the numbers need only be multiplied together.” Id. at 15 1101. 16 2. Ameri-Force’s Methodology and Plaintiff’s Objections 17 Here, the Complaint does not specify an amount in controversy. For each of the first 18 eight causes of action, the Complaint alleges a period of time during which Defendants “at 19 times” violated the applicable labor laws. E.g., ECF No.

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Carroll v. Ameri-Force Craft Services, Inc.., Counsel Stack Legal Research, https://law.counselstack.com/opinion/carroll-v-ameri-force-craft-services-inc-casd-2025.