Gist-Reed v. Alpha Analytical Laboratories, Inc.

CourtDistrict Court, E.D. California
DecidedJune 4, 2025
Docket2:24-cv-03282
StatusUnknown

This text of Gist-Reed v. Alpha Analytical Laboratories, Inc. (Gist-Reed v. Alpha Analytical Laboratories, 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
Gist-Reed v. Alpha Analytical Laboratories, Inc., (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 LAURYN GIST-REED, individually, and No. 2:24-cv-03282-DJC-CSK on behalf of all others similarly 12 situated, 13 Plaintiff, ORDER

14 v.

15 ALPHA ANALYATICAL LABORATORIES, INC., a California 16 corporation; and DOES 1 through 10, inclusive, 17 Defendants. 18

19 20 Under the Class Action Fairness Act (“CAFA”), a defendant to a class action 21 lawsuit can remove the suit from state court to federal court if certain federal 22 jurisdiction requirements are met. Here, Defendant Alpha Analytical Laboratories, Inc. 23 did so, but after a delay of several months. Plaintiff Lauryn Gist-Reed asks this Court to 24 remand the case to the state court, arguing that Alpha Analytical filed outside CAFA’s 25 statutory time frame for remand, and that even if the removal was proper, there is an 26 applicable CAFA exemption. For the reasons discussed below, the Court finds that 27 Defendant’s removal under CAFA was proper and that the local controversy 28 1 exemption to CAFA does not apply. Accordingly, the Court declines to remand the 2 case to state court. 3 FACTS AND PROCEDURAL HISTORY 4 Plaintiff Lauryn Gist-Reed is a resident of Tennessee,1 who, from approximately 5 October 2023 to November 2023, worked as an hourly-paid, nonexempt Lab 6 Technician for Defendant Alpha Analytical Laboratories, Inc. (“Alpha Analytical”) in 7 California.2 (ECF No. 1, containing First Amended Complaint (Ex. I), hereinafter “FAC,” 8 ¶¶ 8, 14.) On February 28, 2024, Plaintiff filed her original complaint bringing seven 9 employment-related claims against Defendant. (ECF No. 1, containing original 10 Complaint (Ex. A), ¶ 2.) On June 10, 2024, she filed a First Amended Complaint, 11 adding two additional claims against Defendant.3 (See generally, FAC.) Neither 12 complaint contained a specified damages amount or an amount in controversy. On 13 November 25, 2024, Defendant removed the case to this Court under CAFA. (ECF 14 No. 1, containing Petition for Removal.) On February 19, 2025, the parties stipulated 15 to waive oral argument, and the matter was deemed submitted. (ECF Nos. 18, 19.) 16 LEGAL STANDARD 17 “[A]ny civil action brought in a State court of which the district courts of the 18 United States have original jurisdiction, may be removed by the defendant or the 19 defendants, to the district court of the United States for the district . . . where such 20 action is pending.” 28 U.S.C. § 1441(a). Under CAFA, federal courts have original 21

22 1 In her FAC filed June 10, 2024, Plaintiff asserts that she is a resident of California. But, Defendant provides evidence that Plaintiff moved to Tennessee on June 5, 2024. Defendant attaches copies of 23 internet posts indicating that Plaintiff permanently moved to Tennessee on that date. (See ECF No. 1, containing Declaration of Kelly Ann Buschman, Exs. A and B.) Plaintiff does not meaningfully rebut this 24 evidence. Because Plaintiff moved five days before the filing of the FAC, the Court accepts that she is not a resident of California. See 28 U.S.C. § 1332(d)(7) (citizenship of the proposed plaintiff is pegged 25 to the filing date of the operative complaint).

26 2 Plaintiff states that she worked for Defendant’s Sacramento location (FAC ¶ 8) and Los Angeles location (FAC ¶ 14). 27 3 In her Motion to Remand, Plaintiff states there are ten causes of action. (ECF No. 14 at 2.) However, 28 the FAC lists only nine causes of action. (See generally, FAC.) 1 jurisdiction over class actions in which the parties are minimally diverse, the proposed 2 class has at least 100 members, and the aggregated amount-in-controversy exceeds 3 $5 million dollars. See 28 U.S.C. § 1332(d)(2), (d)(5), (d)(6), hereinafter “CAFA.” 4 A defendant removing a class action filed in state court pursuant to CAFA need 5 only plausibly allege in the petition for removal that the CAFA prerequisites are 6 satisfied. Dart Cherokee Basin Operating Co. v. Owens, 574 U.S. 81, 87 (2014). If the 7 plaintiff contests the alleged amount in controversy, however, the defendant bears the 8 evidentiary burden of establishing by a preponderance of the evidence that the 9 amount in controversy exceeds $5 million. See id. at 88 (quoting 28 U.S.C. 10 § 1446(c)(2)(B)); see also Rodriguez v. AT&T Mobility Servs. LLC, 728 F.3d 975, 978, 11 982 (9th Cir. 2013). “If at any time before final judgment it appears that the district 12 court lacks subject matter jurisdiction, the case shall be remanded.” 28 U.S.C. 13 § 1447(c); see Smith v. Mylan, Inc., 761 F.3d 1042, 1044 (9th Cir. 2014). The Supreme 14 Court has advised, however, “that no antiremoval presumption attends cases invoking 15 CAFA” in part because the statute was enacted “to facilitate adjudication of certain 16 class actions in federal court.” Dart Cherokee, 574 U.S. at 89 (citations and quotations 17 omitted); see Ibarra v. Manheim Investments., Inc., 775 F.3d 1193, 1197 (9th Cir. 2015) 18 (“Congress intended CAFA to be interpreted expansively.”). 19 DISCUSSION 20 Plaintiff argues that Defendant improperly removed this suit under CAFA. For 21 the reasons discussed below, the Court disagrees and finds that Defendant’s removal 22 of this case was properly effectuated under CAFA. The Court also finds that Plaintiff 23 has not met her burden of proof to establish that the local controversy exemption 24 applies. 25 A. Defendant Properly Removed This Suit Under CAFA 26 Typically, removal under CAFA must be initiated “within 30 days after receipt by 27 the defendant, through service or otherwise, of a copy of the initial pleading setting 28 forth the claim for relief upon which such action or proceeding is based.” 28 U.S.C. 1 § 1446(b)(1). Then, three jurisdictional requirements must be satisfied: (1) the parties 2 must be diverse, (2) the proposed class must be over 100 members, and (3) the 3 aggregated amount-in-controversy must exceed $5 million dollars. Id. § 1332(d)(2), 4 (d)(5), (d)(6). If the initial documents do not facially satisfy the elements of removal, a 5 defendant is able to remove a suit within thirty days “from which it is ascertainable that 6 the case is removable.” Roth v. CHA Hollywood Med. Ctr., L.P., 720 F.3d 1121, 1124 7 (9th Cir. 2013); see 28 U.S.C. § 1446(b)(3). 8 1. The Removal Was Timely 9 The threshold question the Court must address is whether Defendant timely 10 removed the suit under CAFA. It did. While Defendant’s removal of the case came 11 substantially after the initial thirty-day window from when Plaintiff filed her FAC, 12 Plaintiff’s FAC failed to facially satisfy the elements of removal. Plaintiff’s FAC did not 13 specify that the parties were diverse, failed to identify the number of potential class 14 members, and did not include an alleged amount in controversy, thereby requiring 15 Defendant to independently assess the viability of removal under CAFA.

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Gist-Reed v. Alpha Analytical Laboratories, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/gist-reed-v-alpha-analytical-laboratories-inc-caed-2025.