Cunningham v. Columbia State Bank

CourtDistrict Court, E.D. California
DecidedJune 18, 2025
Docket2:25-cv-01036
StatusUnknown

This text of Cunningham v. Columbia State Bank (Cunningham v. Columbia State Bank) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cunningham v. Columbia State Bank, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 UNITED STATES DISTRICT COURT 6 EASTERN DISTRICT OF CALIFORNIA 7 8 MARCUS CUNNINGHAM, an individual, No. 2:25-cv-01036-JAM-SCR 9 Plaintiff, 10 v. ORDER GRANTING PLAINTIFF’S MOTION TO REMAND 11 COLUMBIA STATE BANK, a Washington limited liability company; UMPQUA 12 BANK, an Oregon limited liability company; CHIVVAS CARLSON, an 13 individual; and DOES 1-10, inclusive, 14 Defendants. 15 16 Before the Court is Marcus Cunningham’s (“Plaintiff”) motion 17 to remand. See Mot., ECF No. 7. Columbia State Bank, Umpqua 18 Bank, and Chivvis Carlson (collectively, “Defendants”) oppose. 19 See Opp’n, ECF No. 12. Plaintiff replied, though he failed to 20 comply with the Court’s order regarding the length of his brief. 21 See Reply, ECF No. 13; Order re Filing Requirements at 1, ECF No. 22 3-2. For the following reasons, Plaintiff’s motion is granted.1 23 I. FACTUAL ALLEGATIONS AND PROCEDURAL BACKGROUND 24 This controversy arises out of Plaintiff’s employment and 25 subsequent termination by Defendants. Compl. ¶¶ 9, 65, ECF No. 26

27 1This motion was determined to be suitable for decision without oral argument. E.D. Cal. L.R. 230(g). The hearing was 28 scheduled for June 17, 2025. 1 7-2. Plaintiff alleges he made complaints about a coworker’s 2 noncompliance with bank policy and a separate coworker’s racist 3 remarks. Id. ¶¶ 14-18, 27-33. Instead of having his complaints 4 taken seriously, Plaintiff pleads that he was retaliated against 5 and terminated. Id. ¶ 65. In his complaint, Plaintiff brings 6 seven causes of action: (1) discrimination in violation of 7 California’s Fair Employment and Housing Act (“FEHA”); 8 (2) harassment in violation of FEHA; (3) retaliation in violation 9 of FEHA; (4) failure to prevent discrimination and retaliation; 10 (5) whistleblower retaliation; (6) wrongful termination in 11 violation of public policy; and (7) defamation. Id. ¶¶ 67-118. 12 Plaintiff originally filed suit in the Superior Court of 13 California, County of Sacramento. Notice of Removal, ECF No. 1. 14 Defendants timely removed the case to federal court under 15 diversity jurisdiction. Id. Plaintiff is purportedly a citizen 16 of California, and while Defendants concede Carlson is also a 17 citizen of California, they argue she was fraudulently joined and 18 therefore should not be considered for purposes of establishing 19 diversity jurisdiction. Id. at 4-5. After removal, Defendants 20 moved to dismiss all causes of action for failure to state a 21 claim. Motion to Dismiss, ECF No. 4. Defendants’ motion is 22 still pending before this Court. 23 Plaintiff now moves to remand this action to state court, 24 arguing that Carlson was not fraudulently joined because he has 25 properly alleged claims against Carlson for harassment, 26 whistleblower retaliation, and defamation (the Second, Fifth, and 27 Seventh Causes of Action, respectively). Mot. at 4-8. 28 Defendants disagree, contending that Plaintiff cannot sustain any 1 claim against Carlson. Opp’n at 4-11. 2 II. OPINION 3 A. Legal Standard 4 Under 28 U.S.C. Section 1441, a defendant may remove a 5 civil action from state to federal court if there exists 6 original jurisdiction. City of Chicago v. Int’l Coll. of 7 Surgeons, 522 U.S. 156, 163 (1997). “The district courts shall 8 have original jurisdiction of all civil actions arising under 9 the Constitution, laws, or treaties of the United States.” 28 10 U.S.C. § 1331. Courts strictly construe the removal statute 11 against removal and federal jurisdiction must be rejected if 12 there is any doubt as to the right of removal. Gaus v. Miles, 13 Inc., 980 F.2d 564, 566 (9th Cir. 1992). The party removing a 14 case to federal court “has the burden to prove, by a 15 preponderance of the evidence, that removal is proper.” 16 Geographic Expeditions, Inc. v. Estate of Lhotka ex rel. Lhotka, 17 599 F.3d 1102, 1107 (9th Cir. 2010). 18 B. Diversity Jurisdiction 19 A court may exercise diversity jurisdiction over a matter 20 when the amount in controversy exceeds $75,000 and there is 21 diversity of citizenship among the parties. See 28 U.S.C. 22 § 1332(a). For diversity purposes, a person is a citizen of a 23 state if he or she is: (1) a citizen of the United States and 24 (2) domiciled in that state. Kantor v. Wellesley Galleries, 25 Ltd., 704 F.2d 1088, 1090 (9th Cir. 1983). An LLC is a citizen 26 of the state of which its owners or members are citizens. 27 Johnson v. Columbia Props. Anchorage, LP, 437 F.3d 894, 899 (9th 28 Cir. 2006). “In determining whether a civil action is removable 1 on the basis of [diversity jurisdiction], the citizenship of 2 defendants sued under fictitious names shall be disregarded.” 28 3 U.S.C. § 1441(b)(1). 4 Regarding the amount in controversy, Plaintiff did not plead 5 an amount of damages. Because Defendants provide a plausible 6 allegation that the amount in controversy is sufficient, and 7 because Plaintiff does not contest this allegation, the Court 8 accepts Defendants’ allegation as true for purposes of this 9 motion. See Notice of Removal at 5-7; Dart Cherokee Basin 10 Operating Co., LLC v. Owens, 574 U.S. 81, 89 (2014). 11 This dispute boils down to whether there is complete 12 diversity of citizenship. Plaintiff and Defendants agree on the 13 following: Plaintiff is a citizen of California, Columbia State 14 Bank resides in Washington, Umpqua Bank resides in Oregon, and 15 Carlson is a citizen of California. See Compl. ¶¶ 1-4; Notice of 16 Removal at 3-4. They disagree, however, on whether Carlson was 17 fraudulently joined. 18 1. Applicable Law 19 The Ninth Circuit held, “Joinder of a non-diverse defendant 20 is deemed fraudulent, and the defendant’s presence in the lawsuit 21 is ignored for purposes of determining diversity, if the 22 plaintiff fails to state a cause of action against a resident 23 defendant, and the failure is obvious according to the settled 24 rules of the state. Further, the defendant is entitled to 25 present the facts showing the joinder to be fraudulent.” Morris 26 v. Princess Cruises, Inc., 236 F.3d 1061, 1067 (9th Cir. 2001) 27 (cleaned up). A defendant alleging fraudulent joinder carries a 28 “heavy burden,” as there is a “general presumption against 1 [finding] fraudulent joinder.” Hunter v. Philip Morris USA, 582 2 F.3d 1039, 1046 (9th Cir. 2009) (citation omitted). Indeed, “if 3 there is a possibility that a state court would find that the 4 complaint states a cause of action against any of the resident 5 defendants, the federal court must find that the joinder was 6 proper and remand the case to the state court.” Id. (citation 7 omitted). “Fraudulent joinder must be proven by clear and 8 convincing evidence.” Hamilton Materials, Inc. v. Dow Chem. 9 Corp., 494 F.3d 1203, 1206 (9th Cir. 2007) (citation omitted). 10 2. Whistleblower Retaliation 11 a. Stating a Claim 12 Plaintiff brings his whistleblower retaliation claim against 13 Carlson under California Labor Code Section 1102.5, which 14 provides in relevant part:

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