Cosey v. Wal-Mart Louisiana, LLC

CourtDistrict Court, M.D. Louisiana
DecidedAugust 27, 2019
Docket3:19-cv-00554
StatusUnknown

This text of Cosey v. Wal-Mart Louisiana, LLC (Cosey v. Wal-Mart Louisiana, LLC) is published on Counsel Stack Legal Research, covering District Court, M.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cosey v. Wal-Mart Louisiana, LLC, (M.D. La. 2019).

Opinion

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF LOUISIANA

GLYNDLYN COSEY CIVIL ACTION NO. VERSUS 19-554-SDD-EWD WAL-MART LOUISIANA, LLC, WALMART INC., AND WAL-MART REAL ESTATE BUSINESS TRUST

NOTICE AND ORDER

This is a civil action involving claims for damages asserted by Glyndlyn Cosey (“Plaintiff”) based upon the injuries she allegedly sustained on April 8, 2019 when she allegedly slipped and fell on a wet floor mat at the entrance of a Walmart store located in Ascension Parish, Louisiana (the “Accident”).1 On July 19, 2019, Plaintiff filed her Petition for Damages (“Petition”) against Wal-Mart Louisiana, LLC, Walmart, Inc., and Wal-Mart Real Estate Business Trust (collectively, “Defendants”), who are alleged to be the owners/controllers of the Walmart store in question. Plaintiff alleges that she suffered personal injuries as a result of the Accident which were caused by the negligence of Defendants.2 On August 22, 2019, Defendants removed the matter to this Court, alleging diversity jurisdiction under 28 U.S.C. § 1332.3 However, Defendants have not shown that complete diversity exists because their citizenship allegations are deficient. Further, Defendant have not shown that the amount in controversy is met. Proper information regarding the citizenship of all parties, and the amount in controversy, is necessary to establish the Court’s diversity jurisdiction under 28 U.S.C. § 1332.

1 R. Doc. 1-2, ¶¶ III, VI-VII. 2 R. Doc. 1-2, ¶¶ I, III, VIII-X. 3 R. Doc. 1, ¶¶ 5, 14. Complete Diversity Citizenship has been properly alleged as to Defendants in the Notice of Removal.4 However, it is not clear that the parties are diverse because citizenship has not been adequately alleged as to Plaintiff. Specifically, Paragraph 12 of the Notice of Removal states that “Plaintiff is a resident of the State of Louisiana.”5 The Fifth Circuit has explained that, “For diversity

purposes, citizenship means domicile; mere residence in the State is not sufficient.”6 Furthermore, “[f]or adults, domicile is established by physical presence in a place in connection with a certain state of mind concerning one’s intent to remain there.”7 Thus, to properly allege the citizenship of an individual, a party must identify the individual’s domicile. Accordingly, Defendants must properly identify the citizenship of Plaintiff, i.e., her domicile. Amount in Controversy It is not clear from the Notice of Removal or the Petition whether Plaintiff’s claims likely exceed $75,000, exclusive of interests and costs, as required by 28 U.S.C. § 1332. Plaintiff’s Petition merely alleges that she “sustained injuries to her body and mind including, without

limitation, injuries to her left shoulder requiring surgical repair, together with past and future mental anguish and physical suffering; past and future loss of enjoyment of life,” for which Plaintiff seeks “past and future expenses for medical care; impairment; other expenses including,

4 See R. Doc. 1, ¶ 9 (alleging that Walmart, Inc. is a Delaware corporation with its principal place of business in Arkansas); ¶ 10 (alleging that Wal-Mart Louisiana, L.L.C. is a limited liability company whose ultimate underlying member is Wal-Mart Stores East, Inc., an Arkansas corporation with its principal place of business in Arkansas); and ¶ 11 (alleging that Wal-Mart Real Estate Business Trust is a business trust whose beneficial shares are owned 100% by Wal-Mart Property Co., which is a Delaware corporation with its principal place of business in Arkansas. Regarding the citizenship of a trust, see Bynane v. Bank of New York Mellon for CWMBS, Inc. Asset-Backed Certificates Series 2006-24, 866 F.3d 351, 357 (5th Cir. 2017) (when a trust is sued in its own name, it takes the citizenship of each of its members), citing Americold Realty Trust v. Conagra Foods, Inc., ––– U.S. –––, 136 S.Ct. 1012, 1016, 194 L.Ed.2d 71 (2016)). 5 R. Doc. 1, ¶ 12. 6 Mas v. Perry, 489 F.2d 1396, 1399 (5th Cir. 1974) (citations omitted). 7 White v. I.N.S., 75 F.3d 213, 215 (5th Cir. 1996) (citing Mississippi Band of Choctaw Indians v. Holyfield, 490 U.S. 30, 48, 109 S.Ct. 1597, 1608, 104 L.Ed.2d 29 (1989)). without limitation, travel to doctor appointments; and lost wages…[as well as] damages as are reasonable in the premises” and legal interest and costs.8 The Notice of Removal also references the foregoing;9 however, pleading only general injuries and general categories of damages is insufficient to establish that the federal jurisdictional minimum is reached.10 “Courts have

routinely held that pleading general categories of damages, such as ‘pain and suffering, disability, lost wages, loss of earning capacity, medical expenses, etc.,’ without any indication of the amount of the damages sought, does not provide sufficient information for the removing defendant to meet his burden of proving that the amount in controversy is satisfied under the ‘facially apparent’ test.”11 Further, although the Petition references a surgical repair, there is no description regarding the nature or extent of the surgery.12 There is also no description of any other actual injury suffered by Plaintiff, the actual amount of medical expenses Plaintiff has incurred thus far, Plaintiff’s prognosis and recommended future treatment, and whether Plaintiff is working/can work. Defendants have not offered any specific medical information regarding Plaintiff’s injuries, treatment, prognosis, and expenses in support of the amount in controversy.

Further, in the Notice of Removal, Defendants rely on the lack of an allegation by Plaintiff in her Petition that her damages do not exceed the federal jurisdictional minimum as required by

8 R. Doc. 1-2, ¶ X and prayer for damages. 9 R. Doc. 1, ¶ 4. 10 See Davis v. JK & T Wings, Inc., 11-501-BAJ-DLD, 2012 WL 278728, at *3 (M.D. La. Jan. 6, 2012), and cases cited therein. 11 See Anderson v. Swift Transportation Company of Arizona, LLC, No. 18-13, 2018 WL 3341822, at *3 (M.D. La. June 4, 2018) (quoting Davis v. JK & T Wings, Inc., No. 11-501, 2012 WL 278728, at *3 (M.D. La. Jan. 6, 2012) (citing Alderdice v. Lowe’s Home Centers, Inc., No. 09-406, 2010 WL 371027 (M.D. La. Jan. 29, 2010); Nelson v. Wal–Mart Stores, Inc., No. 09-302, 2009 WL 1098905 (W.D. La. Apr. 22, 2009), and numerous cases cited therein, Fontenot v. Granite State Ins. Co., No. 08-1296, 2008 WL 4822283 (W.D. La. Nov. 3, 2008); and Bonck v. Marriot Hotels, Inc., No. 02-2740, 2002 WL 31890932 (E.D. La. Dec. 30, 2002)). 12 See Hays v. Wal-Mart Louisiana, LLC, 09-1003, 2009 WL 10694646, at *3 (W.D. La. Aug. 3, 2009) (finding it was not facially apparent from the petition that amount in controversy was met where the petition stated that the plaintiff sustained an injury that required surgery, but did not provides specifics as to the type of surgery, i.e., “major versus minor, in-patient versus out-patient, or arthroscopic versus invasive.”) La. C.C.P. art. 893(A)(1);13 however, this Court has held that a “plaintiffs’ failure to follow La. C.C.P. art.

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Cosey v. Wal-Mart Louisiana, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cosey-v-wal-mart-louisiana-llc-lamd-2019.