Doe v. Lyft, Inc.

District Court, D. Kansas·Decided September 15, 2025·No. 2:23-cv-02548·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

JANE DOE,

Plaintiff,

v. Case No. 23-2548-JWB-TJJ

LYFT, INC. et al,

Defendants.

MEMORANDUM AND ORDER

This matter came on for hearing August 19, 2025, on Plaintiff’s pending motion to remand this case back to the District Court of Douglas County, Kansas, for lack of subject-matter jurisdiction under 28 U.S.C. § 1447(c). (Doc. 80.) Although motions for remand can generally only be filed within 30 days of removal, motions for remand based on lack of subject matter jurisdiction can be filed any time before final judgement. Grijalva v. Safeway Stores, Inc., 996 F.2d 311 (10th Cir. 1993) (unpublished table decision). This motion was fully briefed prior to the hearing (Doc. 80, 82, 83, 84, 85),1 and the court also heard evidence related to the motion at the hearing. The court now rules on the motion previously taken under advisement. Given that Defendants have failed to meet their burden of showing that complete diversity of citizenship exists, Plaintiff’s motion to remand is GRANTED. This motion turns on the citizenship of Defendant Joshua Williams. Mr. Williams is one of the two Defendants who had been properly served prior to the filing of the present motion.

1 Plaintiff had previously filed a motion to remand on May 27, 2025 (Doc. 69), but the undersigned ordered that motion stricken from the record since it contained unredacted personal information regarding several Defendants. (Doc. 78.) Defendants also filed supplemental evidence in response to the evidence Plaintiff produced at the motion hearing. (Doc. 89.) Plaintiff argues that he is a citizen of Kansas, thereby destroying the grounds for this court’s diversity jurisdiction under 28 U.S.C. §§ 1332, 1441. Defendant contends that Joshua Williams is a citizen of Missouri or, in the alternative, a citizen of Colorado.2 In removing this case from state court, Defendants bear the burden of proving all facts that would allow the court to exercise jurisdiction by a “preponderance of the evidence.” McNutt v.

Gen. Motors Acceptance Corp. of Indiana, 298 U.S. 178, 189 (1936); Karnes v. Boeing Co., 335 F.3d 1189, 1194–95 (10th Cir. 2003). See also Martin v. Franklin Capital Corp., 251 F.3d 1284, 1290 (10th Cir. 2001) (gathering cases). If the jurisdictional facts are contested, the court can look beyond the complaint at other evidence regarding jurisdictional facts including “either interrogatories obtained in state court before removal was filed, or affidavits or other evidence submitted in federal court afterward.” McPhail v. Deere & Co., 529 F.3d 947, 956 (10th Cir. 2008). Although there is some conflicting precedent within the Tenth Circuit on whether evidence uncovered during discovery can be considered for subject matter jurisdiction, “it is appropriate to consider post-removal evidence to determine whether subject-matter jurisdiction exists.”

Thompson v. Intel Corp., No. CIV 12-0620 JB/LFG, 2012 WL 3860748, at *11 (D.N.M. Aug. 27, 2012). In determining whether removal is proper, “[r]emoval statutes are to be strictly construed . . . and all doubts are to be resolved against removal.” Fajen v. Found. Rsrv. Ins. Co., 683 F.2d 331, 333 (10th Cir. 1982). Moreover, in the Tenth Circuit, “there is a presumption against removal jurisdiction.” Laughlin v. Kmart Corp., 50 F.3d 871, 873 (10th Cir. 1995), abrogated on other

2 Defendant argues in the alternative that Joshua Williams could be considered a citizen of Colorado because at the time he was arrested in 2022, he was residing in Colorado with an application for an interstate compact transfer of his then-active probation to Colorado. (Doc 80-16 at 8, 18, 21–22.) Nevertheless, Defendants maintain that he is a citizen of Missouri in their removal notice from Douglas County. (Doc. 1 at ¶ 8.c.) Plaintiff argues that this alternative theory “is inherently self-contradictory” (Doc. 80 at 20), and she also argues that Defendant cannot offer alternative theories of domicile after removal. This is likely an accurate contention as Defendants only pled Joshua Williams was a citizen of Missouri in their removal notice. However, given the disposition of the case as set out infra, the court does not need to address this argument. grounds by Dart Cherokee Basin Operating Co., LLC v. Owens, 574 U.S. 81 (2014). As an initial consideration, “[a]n individual's residence is not equivalent to his domicile and it is domicile that is relevant for determining citizenship.” Siloam Springs Hotel, L.L.C. v. Century Sur. Co., 781 F.3d 1233, 1238 (10th Cir. 2015). To establish domicile in a particular state, a person must be physically present in the state and intend to remain there. Keys Youth Servs., Inc.

v. Olathe, 248 F.3d 1267, 1272 (10th Cir. 2001). “To effect a change in domicile, two things are indispensable: First, residence in a new domicile, and second, the intention to remain there indefinitely.” Crowley v. Glaze, 710 F.2d 676, 678 (10th Cir. 1983). In Kansas, there is a presumption favoring an established domicile over a newly acquired one. Boone v. Raney, 668 F. Supp. 3d 1178, 1192 (D. Kan. 2023). However, the complication in this case is that the civil complaint was filed while Joshua Williams was incarcerated in Kansas. “Because domicile is a voluntary status, a prisoner is presumed to be a citizen of the state of which he was a citizen before his incarceration, even if he is subsequently incarcerated in another state.” Smith v. Cummings, 445 F.3d 1254, 1260 (10th Cir. 2006). Nevertheless, this presumption can be rebutted based on

the actions a prisoner takes while he is incarcerated to establish connections to a new state to stay there indefinitely. Jones v. United States, 305 F. Supp. 2d 1200, 1208 (D. Kan. 2004).3 “Factors to be weighed in determining domicile include the prisoner's declaration of intentions, ‘the possibility of parole ..., the manner in which [he] has ordered his personal and business transactions, and any other factors that are relevant to corroboration of [the prisoner's] statements.’” Smith, 445 F.3d at 1260 (citing Stifel v. Hopkins, 477 F.2d 1116, 1126–27 (6th Cir.

3 When determining domicile in a civil context (apart from an incarcerated individual), “[t]he court pays particular attention to objective indicia of intent such as the place of employment, driver's license, automobile registration, bank accounts, tax payments, location of personal property, and voting practices.

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Doe v. Lyft, Inc., (D. Kan. 2025).

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Related

McNutt v. General Motors Acceptance Corp.
298 U.S. 178 (Supreme Court, 1936)
Keys Youth Services, Inc. v. City of Olathe
248 F.3d 1267 (Tenth Circuit, 2001)
Martin v. Franklin Capital Corp.
251 F.3d 1284 (Tenth Circuit, 2001)
Karnes v. Boeing Company
335 F.3d 1189 (Tenth Circuit, 2003)
Smith v. Cummings
445 F.3d 1254 (Tenth Circuit, 2006)
McPhail v. Deere & Co.
529 F.3d 947 (Tenth Circuit, 2008)
Orville E. Stifel, II v. William F. Hopkins, Esq.
477 F.2d 1116 (Sixth Circuit, 1973)
Jesus M. Grijalva v. Safeway Stores, Inc.
996 F.2d 311 (Tenth Circuit, 1993)
Larry Laughlin v. Kmart Corporation
50 F.3d 871 (Tenth Circuit, 1995)
Jones v. United States
305 F. Supp. 2d 1200 (D. Kansas, 2004)
Siloam Springs Hotel, L.L.C. v. Century Surety Co.
781 F.3d 1233 (Tenth Circuit, 2015)