David Smith v. Consolidated Asset Management Services (California) LLC; Consolidated Asset Management Services California (O&M), LLC; and Does 1 through 50, inclusive

District Court, E.D. California·Decided February 27, 2026·No. 1:25-cv-01988·Unknown

Opinion

DAVID SMITH, No. 1:25-cv-01988-KES-CDB Plaintiff, ORDER DENYING PLAINTIFF’S MOTION TO REMAND WITHOUT PREJUDICE, AND v. GRANTING DEFENDANTS LEAVE TO AMEND MANAGEMENT SERVICES (CALIFORNIA) LLC, a California Limited Liability Company; CONSOLIDATED Doc. 6 CALIFORNIA (O&M), LLC, a California Limited Liability Company; and DOES 1 through 50, inclusive, Defendants. Plaintiff David Smith moves to remand this action to the Superior Court of the State of California for the County of Kern, following removal to the federal court by defendants Consolidated Asset Management Services (California), LLC (“CAMS California”), and Consolidated Asset Management Services California (O&M), LLC (“CAMS O&M”). Doc. 6. This matter is suitable for resolution without a hearing pursuant to Local Rule 230(g). The Court has considered the parties’ briefing and, for the reasons explained below, denies Smith’s motion to remand without prejudice and grants defendants leave to amend their notice of removal. Smith filed this action against his employers CAMS California and CAMS O&M (collectively “CAMS”), and fictious Doe defendants, in Kern County Superior Court on November 19, 2025, alleging various employment-related violations, including discrimination, retaliation, failure to pay wages, failure to accommodate, and failure to engage in the interactive process under several California statutes and California common law. See Doc. 1-1 at 9. In or about July 2019, Smith began working for CAMS as an operator mechanic II. Id. at ¶ 8. On or about January 22, 2025, CAMS placed Smith on a paid leave of absence pending an evaluation by a company physician that Smith was fit for duty. Id. at ¶ 9. Upon completing the evaluation, a physician chosen by CAMS determined that Smith should not work until another physician or neurologist determined he was fit to work. Id. at ¶ 11. CAMS’s human resources business partner, Ana Gutierrez, told Smith about this additional evaluation via email on or about February 13, 2025. Id. at ¶ 12. Because he was unable to schedule an appointment with a neurologist until June 30, 2025, Smith was approved for medical leave and continued his leave of absence. Id. at ¶ 13. While waiting to see a neurologist, another physician evaluated Smith and diagnosed him with Huntington’s Disease on or about May 5, 2025. Id. at ¶ 14. Smith met with a neurologist for the first time on or about June 30, 2025. Id. at ¶ 15. On July 23, 2025, Smith’s primary care physician provided Smith with a doctor’s note clearing him to return to work. Id. at ¶ 17. That same day, Smith emailed a copy of the note to CAMS’s senior human resources business partner, Treasure Williams. Id. at ¶ 18. Later that day, Smith informed Williams that there may have been a misunderstanding when his physician cleared him to return to work, because he needed to complete an electroencephalogram (“EEG”) test before his neurologist would clear him to return to work. Id. at ¶ 21. After Smith had the EEG, Smith’s neurologist provided a note on September 11, 2025, which cleared Smith to return to work immediately. Id. at ¶ 25. Smith emailed Williams a copy of the neurologist’s note that same day. Id. at ¶ 26. Williams confirmed receipt of the neurologist’s note that day and told him that she “will be in touch . . . regarding next steps.” Id. at ¶ 27. On September 15, 2025, Smith emailed Williams asking when he could return to work because he had not yet heard back from her. Id. at ¶ 29. Williams responded the same day that she “will be in contact . . . regarding next steps.” Id. at ¶ 30. From September 17, 2025, through September 22, 2025, Smith reached out to Williams three more times asking for an update, but he received either no response or a response that she was traveling for work. Id. at ¶¶ 32–36. On September 25, 2025, Smith informed Williams that he would be contacting a lawyer. Id. at ¶ 36. On October 3, 2025, CAMS terminated Smith’s employment. Id. at ¶ 37. Separately, Smith alleges that during his employment, CAMS forced him to work through his meal and rest breaks, and to use his personal cell phone for work-related tasks without proper compensation. Id. at ¶¶ 38–41. On December 22, 2025, defendants filed a notice of removal to federal court based on diversity jurisdiction. Doc. 1 at ¶ 2. On January 21, 2026, Smith moved to remand on the basis that CAMS California and CAMS O&M are non-diverse parties. Doc. 6 at 2. On February 4, 2026, defendants filed an opposition to the motion to remand, to which Smith replied on February 13, 2026. Docs. 7, 8. A suit filed in state court may be removed to federal court if the court would have original jurisdiction over the suit. 28 U.S.C. § 1441(a). Removal is proper when a case originally filed in state court presents a federal question or where there is diversity of citizenship among the parties and the amount in controversy exceeds $75,000. See 28 U.S.C. §§ 1331, 1332(a). Defendants desiring to remove a civil action to federal court must file a notice of removal “containing a short and plain statement of the grounds for removal.” 28 U.S.C. § 1446(a). In the notice of removal defendants need only allege that the parties are diverse and that the amount in controversy exceeds $75,000. See Ellenburg v. Spartan Motors Chassis, Inc., 519 F.3d 192, 200 (4th Cir. 2008); see also Acad. Of Country Music v. Cont’l Cas. Co., 991 F.3d 1059, 1061 (9th Cir. 2021) (endorsing the holding in Ellensburg). But “[i]f at any time before final judgment it appears that the district court lacks subject matter jurisdiction, the case shall be remanded.” 28 U.S.C. § 1447(c). Section 1447(c) “is strictly construed against removal jurisdiction, and the burden of establishing federal jurisdiction falls to the party invoking the statute.” Acad. Of Country Music, 991 F.3d at 1061 (quoting Cal. ex rel. Lockyer v. Dynegy, Inc., 375 F.3d 831, 838 (9th Cir. 2004). A federal court must reject jurisdiction and remand the case to state court if there is any doubt as to the right of removal. Matheson v. Progressive Specialty Ins. Co., 319 F.3d 1089, 1090 (9th Cir. 2003). Nevertheless, when citizenship is at issue, courts have allowed the party asserting diversity jurisdiction the opportunity to demonstrate that the parties are indeed diverse. See, e.g., Delay v. Rosenthal Collins Group, LLC, 585 F.3d 1003, 1005 (6th Cir. 2009) (directing the defendant LLC to submit a jurisdictional statement identifying the citizenship of all its members); U.S. Liability Ins. Co. v. M Remodeling Corp., 444 F. Supp. 3d 408, 410 (E.D.N.Y. 2020) (ordering the plaintiff to show cause why the case should not be dismissed for lack of subject matter jurisdiction); Pentair Flow Techs. v. L.I. Dev. Kan. City, LLC, No. 22-2241, 2022 WL 2290532, at *2 (D. Kan. June 24, 2022) (same). A court may exercise diversity jurisdiction over a matter when there is diversity of citizenship among the parties and the amount in controversy exceeds $75,000. See 28 U.S.C. § 1332(a). For diversity purposes, a person is a citizen of a state if he or she is: (1) a citizen of the Unit

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David Smith v. Consolidated Asset Management Services (California) LLC; Consolidated Asset Management Services California (O&M), LLC; and Does 1 through 50, inclusive, (E.D. Cal. 2026).

David Smith v. Consolidated Asset Management Services (California) LLC; Consolidated Asset Management Services California (O&M), LLC; and Does 1 through 50, inclusive (David Smith v. Consolidated Asset Management Services (California) LLC; Consolidated Asset Management Services California (O&M), LLC; and Does 1 through 50, inclusive) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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