Gallagher-Stevens v. Independent Living Systems, LLC

CourtDistrict Court, N.D. California
DecidedJanuary 31, 2025
Docket3:24-cv-04582
StatusUnknown

This text of Gallagher-Stevens v. Independent Living Systems, LLC (Gallagher-Stevens v. Independent Living Systems, LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gallagher-Stevens v. Independent Living Systems, LLC, (N.D. Cal. 2025).

Opinion

1 2 3 UNITED STATES DISTRICT COURT 4 NORTHERN DISTRICT OF CALIFORNIA 5 6 SAMUEL GALLAGHER-STEVENS, Case No. 24-cv-04582-WHO

7 Plaintiff, ORDER GRANTING MOTION TO 8 v. REMAND

9 INDEPENDENT LIVING SYSTEMS, LLC, Re: Dkt. No. 14 Defendant. 10

11 12 Defendant Independent Living Systems, LLC (“ILS”) removed this putative wage and 13 hour class action from the Superior Court of California, County of San Francisco, pursuant to 28 14 U.S.C. §§ 1332, 1441, 1445, as amended by the Class Action Fairness Act of 2005 (“CAFA”). 15 Plaintiff Samuel Gallagher-Stevens moves to remand it because ILS has not made a sufficient 16 showing that there is more than $5 million in controversy, which is the CAFA jurisdictional 17 threshold for removal to federal court. ILS has significantly overestimated the violation rates for 18 most claims in light of Gallagher-Stevens’s allegations: a reasonable calculation of damages 19 makes clear that the $5 million CAFA threshold has not been met. The motion to remand is 20 GRANTED. 21 BACKGROUND 22 Gallagher-Stevens filed the underlying Complaint on May 6, 2024, “on behalf of a 23 California class, defined as all individuals who are or previously were employed by Defendant in 24 California, including any employees staffed with Defendant by a third party, and classified as non- 25 exempt employees…at any time during the period beginning four (4) years prior to the filing of 26 this Complaint and ending on the date as determined by the Court.” Complaint (“Compl.”) [Dkt. 27 1 1-2] ¶ 4.1 The proposed subclass is defined as, “all members of the California Class who are or 2 previously were employed by Defendant in California, including any employees staffed with 3 Defendant by a third party, and classified as non-exempt employees…at any time during the 4 period three (3) years prior to the filing of the complaint and ending on the date as determined by 5 the Court…pursuant to Cal. Code of Civ. Proc. § 382.” Id. ¶ 35. 6 The Complaint asserts eleven causes of action: (1) unfair competition; (2) failure to pay 7 minimum wages; (3) failure to pay overtime wages; (4) failure to provide required meal periods; 8 (5) failure to provide required rest periods; (6) failure to provide accurate itemized wage 9 statements; (7) failure to reimburse employees for required business expenses; (8) failure to pay 10 wages when due; (9) failure to pay sick pay wages; (10) discrimination and retaliation in violation 11 of the California Fair Employment and Housing Act (“FEHA”); and (11) wrongful termination in 12 violation of public policy. See generally id. Gallagher-Stevens seeks relief on his own behalf and 13 on behalf of the putative class in the form of unpaid minimum wages, unpaid overtime wages, 14 wage statement penalties, meal and rest period compensation, liquidated damages, the cost of 15 unreimbursed business expenses, waiting time penalties, prejudgment interest, and attorney fees, if 16 the plaintiffs prevail. Id., Prayer for Relief. 17 ILS removed the case from the Superior Court of California, County of San Francisco on 18 July 29, 2024. Dkt. No. 1 (Notice of Removal). In support of the Notice of Removal, ILS relied 19 upon the Declaration of Carolina Castillo. Dkt. No. 1-6 (Castillo Declaration). It now relies upon 20 the Declaration of Hassan Assaf, who works with Libra Analytics, a company that “provides 21 expert analysis and consulting services related to labor and employment matters.” Dkt. No. 15-1 22 (Assaf Declaration) ¶¶ 1-2. 23 ILS provided Assaf with estimates of the number of employees in the putative class and 24 the average hourly wage for employees, who are paid bi-weekly. He was only given timekeeping 25 data starting from April 24, 2023—he had to extrapolate that data to estimate relevant numbers 26 from the start of the class period, which is May 6, 2020. He estimates that there is a total of 27 1 $9,2291,133.95 in controversy, which would well exceed the CAFA jurisdictional threshold. See 2 Oppo. 18-19 (chart). • Total Amount in Controversy from Minimum Wage Claim: $1,720,915.12 3 • Total Amount in Controversy from Overtime Claim $465,819.52 4 • Total Amount in Controversy from Meal and Rest Period Claim $4,041,343.56 • Total Amount in Controversy from Wage Statement Claim $433,000 5 • Total Amount in Controversy from Unreimbursed Expenses Claim $139,003.85 • Total Amount in Controversy from Waiting Time Penalties Claim $632,825.11 6 Subtotal: $7,432,907.16 7 • Attorneys’ Fees Benchmark $1,858,226.79 8 Total Amount-In-Controversy: $9,291,133.95. Gallagher-Stevens disputes ILS’s projections for 9 the amount placed in controversy for each category of claims. 10 LEGAL STANDARD 11 A defendant may remove a class action from state to federal court by filing a notice of 12 removal that lays out the grounds for removal. 28 U.S.C. § 1453(b); 28 U.S.C. § 1446(a). The 13 district court must remand the case to state court if it lacks subject matter jurisdiction. 28 U.S.C. § 14 1447(c). For federal jurisdiction under CAFA, the amount in controversy must “exceed[] the sum 15 or value of $5,000,000, exclusive of interest and costs.” 28 U.S.C. § 1332(d)(2)(A). The amount in 16 controversy in the litigation can include “damages, costs of compliance with injunctions, 17 attorneys’ fees awarded under contract or fee shifting statutes ... [and] future attorneys’ fees 18 recoverable by statute or contract.” Fritsch v. Swift Transportation Co. of Arizona, LLC, 899 F.3d 19 785, 794 (9th Cir. 2018). 20 The Ninth Circuit applies “the longstanding rule that the party seeking federal jurisdiction 21 on removal bears the burden of establishing that jurisdiction.” Abrego Abrego v. The Dow 22 Chemical Co., 443 F.3d 676, 686 (9th Cir. 2006). When the plaintiff challenges the amount-in- 23 controversy allegations in a notice of removal, parties should submit proof so that the court can 24 determine whether the jurisdictional amount has been shown by a preponderance of the evidence. 25 Dart Cherokee Basin Operating Co., LLC v. Owens, 574 U.S. 81, 83-85 (2014); Ibarra v. 26 Manheim Investments, Inc., 775 F.3d 1193, 1197 (9th Cir. 2015) (noting that after the amount in 27 controversy has been challenged, the parties may submit affidavits, declarations, or other 1 summary-judgment-type evidence to the court). If the complaint does not include an amount in 2 controversy, the defendant has the burden to “persuade the court that [its] estimate of damages in 3 controversy is a reasonable one.” Ibarra, 775 F.3d at 1197. The plaintiff’s motion to remand will 4 not be successful if it merely challenges the defendant’s assumptions without asserting an 5 alternative. Id. at 1199. 6 The plaintiff may contest the amount in controversy by making either a “facial” or 7 “factual” attack on the defendant’s jurisdictional allegations. See Salter v. Quality Carriers, 974 8 F.3d 959, 964 (9th Cir. 2020). “A ‘facial’ attack accepts the truth of the [defendant’s] allegations 9 but asserts that they ‘are insufficient on their face to invoke federal jurisdiction.’” Id. (quoting 10 Leite v. Crane Co., 749 F.3d 1117, 1121 (9th Cir. 2014)).

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Gallagher-Stevens v. Independent Living Systems, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gallagher-stevens-v-independent-living-systems-llc-cand-2025.