Celena King v. Great Am. Chicken Corp., Inc. d/b/a Kentucky Fried Chicken, et al.

District Court, C.D. California·Decided January 25, 2018·No. 2:17-cv-04510·Unknown

Opinion

CUENNTITREADL S DTIASTTERSIC DTI SOTFR CICATL ICFOOURRNTIA CIVIL MINUTES - GENERAL Case No. CV 17-4510-GW(ASx) Date January 25, 2018 Title Celena King v. Great Am. Chicken Corp., Inc. d/b/a Kentucky Fried Chicken, et al.,

Present: The Honorable GEORGE H. WU, UNITED STATES DISTRICT JUDGE Javier Gonzalez Katie Thibodeaux Deputy Clerk Court Reporter / Recorder Tape No. Attorneys Present for Plaintiffs: Attorneys Present for Defendants: Kayvon Sabourian Mark D. Kemple Launa Adolph Ashley Michelle Farrell PROCEEDINGS: PLAINTIFF’S MOTION TO REMAND [38] The Court’s Tentative Ruling is circulated and attached hereto. Court hears oral argument. For reasons stated on the record, Plaintiff’s Motion is TAKEN UNDER SUBMISSION. Court to issue ruling.

: 25 King v. Great Am. Chicken Corp, Inc., Case No. 2:17-cv-04510-GW-(ASx) Tentative Ruling on Motion to Remand

Great American Chicken Corp, Inc. (“Defendant”) removed this case to federal court on June 19, 2017,1 citing the Class Action Fairness Act (“CAFA”), 28 U.S.C. § 1332(d), as the basis for this Court’s subject matter jurisdiction. Celena King (“Plaintiff”) does not contest this basis for subject matter jurisdiction, or otherwise argue that federal subject matter jurisdiction is lacking here. However, she has filed a motion to remand arguing that the Court must decline jurisdiction under other provisions of CAFA because over two-thirds of the members of her putative class are citizens of California and other statutory requirements for such a declination are met. A federal court must decline jurisdiction over a “minimal diversity” class action such as this if two-thirds or more of the members of the proposed class(es), in the aggregate, and the primary defendants are citizens of the state in which the action was originally filed. See 28 U.S.C. § 1332(d)(4)(B); see also O’Connell & Stevenson, California Practice Guide: Federal Civil Procedure Before Trial (2017) (“O’Connell & Stevenson”) ¶ 2:1445, at 2C-45. This is referred to within the relevant case law as the “home state” exception to CAFA jurisdiction. In addition, a federal court must decline jurisdiction over such a class action where more than two-thirds of the class members and at least one defendant are “citizens” of that state and the alleged wrongdoing occurred there, “significant relief” is being sought from the local defendant whose alleged conduct forms a “significant basis” for the plaintiff’s claims, and no other class action has been filed within the past three years on behalf of the same persons against any defendant asserting the same or similar factual allegation. See 28 U.S.C. ¶ 1332(d)(4)(A). This is referred to within the relevant case law as the “local controversy” exception. Plaintiff moves for remand under both exceptions. The only aspect of either the “home state” exception or the “local controversy” exception that is disputed here is whether Plaintiff has satisfied her burden, see Allen v. Boeing Co., 821 F.3d 1111, 1116 (9th Cir. 2016), to demonstrate that two-thirds or more of

1 The case was originally filed in the Superior Court of the State of California, County of Los Angeles on January 10, 2017. See Notice of Removal ¶ 5; Docket No. 1-1. the putative class members are citizens of California. At the time of removal, the putative class in this case was defined as “all current and former non-exempt employees of DEFENDANTS in the State of California at any time within the period beginning four (4) years prior to the filing of this action and ending at the time this action settles or proceeds to final judgment.” See First Amended Complaint, Docket No. 1-2, ¶ 5. The proposed class definition remains the same in the operative Third Amended Complaint. See Docket No. 24, ¶ 8. The parties have stipulated to the fact that at least 67% of the last-known addresses for putative class members are in California. See Docket No. 30; Docket No. 36, at 3:18-24, 4:21-24, 8:7-11, 11:14-24. They apparently reached this stipulation in lieu of taking discovery bearing on the point. See generally Mondragon v. Capital One Auto Finance, 736 F.3d 880, 885-86 (9th Cir. 2013). Defendant believes there are a number of reasons why this stipulation does not do the trick for Plaintiff in light of her burden. For one thing, it emphasizes that residence does not equate to citizenship. In addition, it argues that even if it did, using an address that an employee (who worked for it at some point in time in the five-year period prior to the Complaint’s filing) gave it at some point in time during that individual’s employment does not reveal where the person was living – much less the person’s citizenship – at the time of removal. There is some uncertainty in the case law concerning what role evidence of residence can play, in line with Plaintiff’s burden, in satisfying the requisite elements of the “home state” and/or “local controversy” exception. As an initial matter, the Court notes that a leading practice guide – apparently basing its statement entirely upon a 2015 decision from the Eighth Circuit Court of Appeals, discussed further below – states that “plaintiffs in a class action cannot use last known addresses to establish citizenship,” commenting further “[t]hat a class member may have a residential address in a state does not mean he or she is a citizen of that state.” O’Connell & Stevenson ¶ 2:1446, at 2C-45 (citing Hood v. Gilster-Mary Lee Corp., 785 F.3d 263, 265-66 (8th Cir. 2015)) (emphasis added). But Ninth Circuit authority certainly does not appear to prohibit use of such evidence – in fact, as discussed below, the Ninth Circuit appears to reject such a notion – even if it does stop short of indicating that such evidence would be sufficient by itself. The Ninth Circuit has indeed observed “[t]hat a purchaser may have a residential address in California does not mean that person is a citizen of California.” Mondragon, 736 F.3d at 884. But Mondragon was not a case involving employment in California. Nor did it even confront any evidence of class members’ residential addresses (meaning that the quoted statement would be, technically, dicta). Instead, it simply involved a class that had been defined “to be limited to persons who ‘purchased a vehicle in California for personal use to be registered in the State of California.’” Id. at 883. The Ninth Circuit “imagine[d] that some automobiles were purchased and registered in California by members of the military, by out-of-state students, by owners of second homes, by other temporary residents who maintained legal citizenship in other states, and by persons who live in California but are not U.S. citizens.” Id. at 884. It is not at all clear that similar sufficiently-serious questions would be raised in a case that, by definition, is limited to individuals who were employed in California.2 Moreover, unlike here, the plaintiff in Mondragon “presented no evidence” to support the proposition that members of such a class would “necessarily be California citizens.” Id. The Ninth Circuit noted that remand under Section 1332(d)(4) could not be based “simply on a plaintiff’s allegations,” and that “[a] complete lack of evidence” did not satisfy the applicable preponderance of the evidence standard. Id. at 884; see also Brinkley v. Monterey Fin’l Servs., Inc., 873 F.3d 1118, 1121 (9th Cir. 2017).

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Celena King v. Great Am. Chicken Corp., Inc. d/b/a Kentucky Fried Chicken, et al., (C.D. Cal. 2018).

Celena King v. Great Am. Chicken Corp., Inc. d/b/a Kentucky Fried Chicken, et al. (Celena King v. Great Am. Chicken Corp., Inc. d/b/a Kentucky Fried Chicken, et al.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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