Chavez Valdez v. Field Asset Services, Inc.

CourtDistrict Court, S.D. California
DecidedAugust 17, 2023
Docket3:23-cv-01085
StatusUnknown

This text of Chavez Valdez v. Field Asset Services, Inc. (Chavez Valdez v. Field Asset 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
Chavez Valdez v. Field Asset Services, Inc., (S.D. Cal. 2023).

Opinion

1 2 3 4 5 6 7 8 9 10 UNITED STATES DISTRICT COURT 11 SOUTHERN DISTRICT OF CALIFORNIA 12 13 ALMA ANGELICA CHAVEZ VALDEZ, Case No.: 23-CV-1085 W (KSC)

14 Plaintiff, ORDER REMANDING CASE TO 15 v. THE SAN DIEGO SUPERIOR COURT 16 FIELD ASSET SERVICES, INC., et al., 17 Defendants. 18 19

20 On April 17, 2023, Plaintiff Alma Angelica Chavez Valdez filed a complaint in the 21 San Diego Superior Court alleging four causes of action. (See Notice of Removal [Doc. 1] 22 Ex. 1 [Doc. 1-3].) On June 10, 2023, Defendants removed the case to this Court asserting 23 jurisdiction under the Class Action Fairness Act (“CAFA”). (Id. 2:24–27.) Because 24 Valdez’s lawsuit is not a class action, on July 10, 2023, this Court ordered Defendants to 25 show cause why the case should not be remanded for lack of subject-matter jurisdiction. 26 (See OSC [Doc. 5].) On July 17, 2023, Defendants filed their response and on July 19, 27 2023, Valdez filed her response. The Court finds the matter appropriate for resolution on 28 the papers. See Civ.L.R. 7.1d1. For the reasons stated below, the Court finds it lacks 1 subject-matter jurisdiction and ORDERS the case remanded to the San Diego Superior 2 Court. 3 4 I. DISCUSSION 5 “Federal courts are courts of limited jurisdiction. They possess only that power 6 authorized by Constitution and statute.” Kokkonen v. Guardian Life Ins. Co. of Am., 511 7 U.S. 375, 377 (1994) (citation omitted). The burden of establishing subject-matter 8 jurisdiction rests upon the party asserting jurisdiction. Id. Additionally, district courts 9 “have an independent obligation to determine whether subject matter jurisdiction exists, 10 even in the absence of a challenge from any party.” Ruhrgas AG v. Marathon Oil Co., 11 526 U.S. 574, 583 (1999); see Fed.R.Civ.P. 12(h)(3) (requiring the court to dismiss the 12 action if subject matter jurisdiction is lacking). Consistent with these principles, the 13 removal statute “is strictly construed, and any doubt about the right of removal requires 14 resolution in favor of remand. The presumption against removal means that the 15 defendant always has the burden of establishing that removal is proper.” Moore-Thomas 16 v. Alaska Airlines, Inc., 553 F.3d 1241, 1244 (9th Cir. 2009) (internal citation and 17 quotation marks omitted). Whether subject-matter jurisdiction exists is to be determined 18 from the complaint. See Snavely v. Johnson, 2015 WL 52429254, at 1–2 (N.D.Cal. Sept. 19 8, 2015) (citations omitted). 20 Before Plaintiff Valdez filed her state-court lawsuit, she was a putative class 21 member of a lawsuit filed against Defendant Field Asset Services and other defendants 22 alleging misclassification and other California Labor Code violations. (Notice of 23 Removal 2:11–16.) The class action, entitled Bowerman et al. v. Field Asset Services, 24 Inc. et al., No. 3:13-cv-00057 (“Bowerman”), was filed in the Northern District of 25 California. (Id.) Although the class was initially certified by the district court, 26 Defendants appealed the decision and on July 5, 2022, the Ninth Circuit decertified the 27 class in a published opinion. (Id. at 2:17–21, citing Bowerman v. Field Asset Servs., Inc., 28 39 F.4th 652, 658 (9th Cir. 2022), as amended, 60 F.4th 459 (9th Cir. 2023).) 1 After Bowerman was decertified, Valdez filed this lawsuit in the San Diego 2 Superior Court. Defendants then removed the case, citing CAFA as the sole basis for 3 subject-matter jurisdiction. (Notice of Removal at 2:24–27.) 4 For CAFA jurisdiction to exist, Valdez’s state-court lawsuit must involve (a) a 5 class size of at least 100 members, (b) at least one plaintiff and one defendant that are 6 citizens of different states, and (c) an aggregate amount in controversy exceeding $5 7 million, exclusive of interest and costs. 28 U.S.C. § 1332(d)(2),(5),(6). “Subject matter 8 jurisdiction is determined from the face of the complaint.” See Snavely v. Johnson, 2015 9 WL 5242925, at *1 (N.D.Cal. Sept. 8, 2015) (citing Toumajian v. Frailey, 135 F.3d 648, 10 653 n.2 (9th Cir. 1998) and Caterpillar, Inc. v. Williams, 482 U.S. 386, 932 (1987)). 11 Based on Vadez’s Complaint, two of the CAFA requirements are missing: Valdez is the 12 only named plaintiff and there are no class allegations (Compl. ¶ 4); and there are no 13 allegations remotely suggesting the aggregate amount in controversy exceeds $5 million 14 (see id.). 15 In their response to the OSC, Defendants argue that subject-matter jurisdiction 16 nevertheless exists because the “Northern District has retained federal jurisdiction over 17 Plaintiff’s individual claims at issue in the Bowerman case.” (Defs’ OSC Response [Doc. 18 7] at 2:3–5.) As a matter of fact, this argument is false. Valdez is not mentioned 19 anywhere in the Bowerman First Amended Complaint (“FAC”), which is attached to 20 Defendants’ Notice of Removal. (See Notice of Removal, Exhibit 2 [Doc. 1-4].) Nor 21 have Defendants cited any orders from the district court presiding over Bowerman 22 indicating that it somehow retained jurisdiction over Valdez’s claims. 23 Defendants also argue the “great weight of authority from California district courts 24 and other circuits supports holding that federal courts retain jurisdiction of Plaintiff’s 25 individual claims despite the decertification of the Bowerman class.” (Defs’ OSC 26 Response at 1:16–27.) In support of this argument, Defendants cite cases that stand for 27 the well-settled principle that CAFA jurisdiction is determined at the time of removal and 28 that subsequent developments do not divest the court of jurisdiction over the case or the 1 claims of named plaintiffs. See Vega v. T-Mobile USA, Inc., 564 F.3d 1256, n. 12 (11th 2 Cir. 2009) (recognizing that “because jurisdictional facts are assessed at the time of 3 removal,” subject-matter jurisdiction continues to exist even if a narrowed class resulted 4 in fewer than 100 class members); United Steel, Paper & Forestry, Rubber Mgf., Energy, 5 Allied Indus. & Serv. Workers Int'l Union v. Shell Oil Co., 602 F3d 1087, 1091–1092 (9th 6 Cir. 2010) (held that denial of class certification does not divest the district of subject 7 matter jurisdiction over the same case); and Ellison v. Autozone Inc., 486 F. App’x 674, 8 675 (9th Cir. 2012) (reversing district court’s remand of a CAFA class action after the 9 plaintiff dismissed the class claims because “[w]here, as here, jurisdiction was proper at 10 the time of removal, subsequent dismissal or transfer of class claims does not defeat the 11 court’s CAFA jurisdiction over remaining individual claims.”) (citing United Steel, 602 12 F.3d at 1092). The problem with these cases is that they do not address whether CAFA 13 jurisdiction covers a subsequently filed state-court lawsuit by a former unnamed, putative 14 class member. 15 Defendants also cites two cases discussing whether CAFA jurisdiction exists over 16 cases that resulted from the district court’s severance of named plaintiffs from the CAFA 17 class action. See Louisiana v. American National Property & Casualty Company, 746 18 F.3d 633 (5th Cir.

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

Related

Vega v. T-MOBILE USA, INC.
564 F.3d 1256 (Eleventh Circuit, 2009)
Sosna v. Iowa
419 U.S. 393 (Supreme Court, 1975)
Caterpillar Inc. v. Williams
482 U.S. 386 (Supreme Court, 1987)
Ruhrgas Ag v. Marathon Oil Co.
526 U.S. 574 (Supreme Court, 1999)
United States v. William M. Davis, Ashland, Inc.
261 F.3d 1 (First Circuit, 2001)
Lynnetta Ellison v. Autozone Inc
486 F. App'x 674 (Ninth Circuit, 2012)
Moore-Thomas v. Alaska Airlines, Inc.
553 F.3d 1241 (Ninth Circuit, 2009)
United States v. Sanchez-Gomez
584 U.S. 381 (Supreme Court, 2018)
Fred Bowerman v. Field Asset Services, Inc.
60 F.4th 459 (Ninth Circuit, 2022)
Toumajian v. Frailey
135 F.3d 648 (Ninth Circuit, 1998)

Cite This Page — Counsel Stack

Bluebook (online)
Chavez Valdez v. Field Asset Services, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/chavez-valdez-v-field-asset-services-inc-casd-2023.