Eric Hibbard v. Walmart, Inc.

CourtDistrict Court, E.D. California
DecidedMay 11, 2026
Docket1:25-cv-00886
StatusUnknown

This text of Eric Hibbard v. Walmart, Inc. (Eric Hibbard v. Walmart, Inc.) 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
Eric Hibbard v. Walmart, Inc., (E.D. Cal. 2026).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 ERIC HIBBARD, Case No. 1:25-cv-00886 JLT CDB

12 Plaintiff, ORDER GRANTING MOTION TO REMAND

13 (Doc. 7) v. 14 WALMART, INC., et al., 15 Defendants. 16 17 Eric Hibbard moves to remand his lawsuit against his former employer, Walmart, Inc., 18 and a district manager. (Doc. 7.) Walmart removed the case to federal court based on its 19 allegation that the claims against the manager were a “sham,” intended to deprive this court of 20 jurisdiction. (See Doc. 1.) Walmart has not demonstrated that the manager cannot be liable under 21 any theory, so the action must be remanded. The motion is GRANTED. 22 ALLEGATIONS 23 Hibbard alleges he began working at a Walmart store in Tehachapi, California, in 24 December 2022. (Doc. 1-1 at 4.) A few months later, he began to have “significant pain in his 25 feet.” (Id.) He spoke with his supervisor, and a doctor provided by Walmart recommended “a 26 short medical leave” before returning to work with restrictions on the time he spent on his feet 27 and the amount of weight he lifted. (Id. at 4–5.) When he returned to work, no one spoke with 28 him about his condition, which he describes as a “disability” in his complaint, nor about any 1 accommodations that might have been appropriate. (Id. at 5.) Instead, the store manager and HR 2 manager “summoned” and “harshly admonished” him for taking leave and for using a scooter to 3 get around the store. (Id.) When he explained his disability and the doctor’s recommendations, 4 they put him on a leave of absence and demanded that he see another doctor in Bakersfield. (Id.) 5 Hibbard visited the doctor in Bakersfield, who diagnosed him with Achilles tendinosis and 6 an ankle strain. (Id.) The doctor in Bakersfield also gave him the same recommendations as the 7 doctor he had seen before: spend less time on his feet and limit the amount of weight he carried. 8 (See id.) When Hibbard asked for an accommodation in line with these recommendations, his 9 supervisors did not respond and instead “continued” his leave of absence. (Id.) He filed an 10 internal complaint, but to no avail. (Id. at 5–6.) The third-party administrator of Walmart’s leave 11 program advised Hibbard to return to work with a “temporary alternative duty” designation. (Id. 12 at 6.) So he did. (Id.) But still, his managers asked him to do work that violated his restrictions. 13 (Id.) When he complained again to HR, nothing changed. (Id.) Instead, the company retaliated 14 against him by reducing his scheduled hours, among other mistreatments. (See id. at 6–7.) He 15 was then terminated based on the pretext that he had been absent from his job. (Id. at 7.) 16 Hibbard complained to the district manager, Naomi Ream. (Id.) She acknowledged that 17 Walmart had wrongfully terminated him and assured him he would be rehired and receive back 18 pay. (Id.) That did not happen. (Id.) His supervisors reduced his hours again and refused his 19 requests for back pay. (Id.) After he spoke to Ream again, Walmart “fabricated attendance 20 violations” and terminated him for a second time. (Id. at 7–8.) Ream did not step in to prevent 21 his second termination. (Id. at 8.) 22 Hibbard filed this lawsuit against Walmart and Ream in state court in 2025. (Doc. 1-1 at 23 2.) Walmart removed the case to this Court under the diversity jurisdiction statute. (Doc. 1 at 3– 24 11.) It contended that Ream’s California citizenship was irrelevant because Hibbard had added 25 her as a “sham” defendant in an attempt to deprive federal courts of jurisdiction. (See id. at 4–5.) 26 Hibbard now moves to remand based on the argument that his claims against Ream are legitimate 27 and viable. (Doc. 7.) Walmart opposes the motion. (Doc. 9.) The Court found that a hearing 28 was not necessary. (Doc. 10.) 1 LEGAL STANDARDS 2 A defendant can remove a case to federal court if the federal court would have had 3 original jurisdiction. 28 U.S.C. § 1441(a). The federal diversity jurisdiction statute gives federal 4 district courts original jurisdiction over cases in which the amount in controversy is greater than 5 $75,000 and the citizenship of each plaintiff differs from the citizenship of each defendant, i.e., 6 when there is “complete diversity.” Grancare, LLC v. Thrower by and through Mills, 889 F.3d 7 543, 548 (9th Cir. 2018) (citing 28 U.S.C. § 1332(a)(1)). “In determining whether there is 8 complete diversity, district courts may disregard the citizenship of a non-diverse defendant who 9 has been fraudulently joined.” Id. 10 One way a removing defendant can show that a non-diverse defendant has been 11 fraudulently joined is by proving that the person “cannot be liable on any theory.” Id. (quoting 12 Ritchey v. Upjohn Drug Co., 139 F.3d 1313, 1318 (9th Cir. 1998)). This is a “‘heavy burden,’ 13 since there is a ‘general presumption against finding fraudulent joinder.’” Id. (alteration omitted) 14 (quoting Hunter v. Philip Morris USA, 582 F.3d 1039, 1044 (9th Cir. 2009)). “[I]f there is a 15 possibility that a state court would find that the complaint states a cause of action against any of 16 the resident defendants, the federal court must find that the joinder was proper and remand the 17 case to the state court.” Id. (emphasis in original) (quoting Hunter, 582 F.3d at 1044). 18 This standard “shares some similarities” with the standard that governs motions to dismiss 19 for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6), but they “are not 20 equivalent.” Id. at 549. “A claim against a defendant may fail under Rule 12(b)(6), but that 21 defendant has not necessarily been fraudulently joined.” Id. Arguments that “go to the 22 sufficiency of the complaint, rather than to the possible viability of the [plaintiff’s] claims” 23 against the non-diverse defendant “do not establish fraudulent joinder.” Id. at 552. For example, 24 if a plaintiff could potentially amend the complaint to assert a viable claim against the non- 25 diverse defendant, then that defendant was not fraudulently joined. See id. at 550. 26 DISCUSSION 27 Hibbard asserts one claim against Ream, for intentional infliction of emotional distress. 28 (Doc. 1-1 at 17–18.) To prevail on this claim at trial, he would need to show, among other things, 1 that Ream’s conduct was “extreme and outrageous” and that she either intended to cause him 2 emotional distress or acted with “reckless disregard of the probability of causing” him emotional 3 distress. Potter v. Firestone Tire & Rubber Co., 6 Cal. 4th 965, 1001 (1993) (quoting 4 Christensen v. Superior Court, 54 Cal. 3d 868, 903 (1991)). Conduct is “outrageous” in the 5 necessary way when it is “so extreme as to exceed all bounds of that usually tolerated in a 6 civilized community.” Id. (quoting Christensen, 54 Cal. 3d at 903). 7 Hibbard’s allegations against Ream fall well short of this mark. He refers to her conduct 8 only three times in his complaint. First, he alleges that she agreed his original termination was 9 “unlawful” and “assured” him that “he would be rehired and receive back pay.” (Id. at 7.) 10 Second, after he was rehired, he alleges Ream “failed to respond” when he complained that his 11 hours had been reduced. (Id.) Third, about a month later, he alleges she “once again failed to 12 take corrective action” after he “informed her that he was still suffering from discrimination and 13 retaliation.” (Id.

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Bluebook (online)
Eric Hibbard v. Walmart, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/eric-hibbard-v-walmart-inc-caed-2026.