Guenther v. Emmons

Court of Appeals for the Ninth Circuit·Decided July 14, 2026·No. 25-3650·Unpublished

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS JUL 14 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

FAYE IRENE GUENTHER, No. 25-3650 D.C. No. Plaintiff - Appellee, 2:22-cv-00272-TOR and MEMORANDUM* UNITED FOOD AND COMMERCIAL WORKERS UNION - LOCAL 3000, UNITED FOOD AND COMMERCIAL WORKERS UNION - LOCAL 1439, UNITED FOOD AND COMMERCIAL WORKERS UNION - LOCAL 21,

Plaintiffs,

v.

JOSEPH H. EMMONS; OSPREY FIELD SERVICES, LLC,

Defendants - Appellants.

Appeal from the United States District Court for the Eastern District of Washington Thomas O. Rice, District Judge, Presiding

Argued and Submitted June 11, 2026 Seattle, Washington

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. Before: M. SMITH and TUNG, Circuit Judges, and HINDERAKER, District Judge.**

Defendants-Appellants Joseph H. Emmons and Osprey Field Services, LLC

appeal the district court’s denial of mandatory attorneys’ fees under RCW 4.84.250,

which awards attorneys’ fees to the “prevailing party” in actions where the “amount

pleaded” is under $10,000. Where, as here, a plaintiff recovers nothing, a defendant

is the prevailing party under RCW 4.84.250. RCW 4.84.270. The district court

found that because it exercised diversity jurisdiction over the matter, the amount in

controversy was necessarily over $75,000 and thus RCW 4.84.250 did not apply.

This Court has jurisdiction over a district court’s final judgment under

28 U.S.C. § 1291. We review legal questions, including questions of statutory

interpretation, de novo. See K.C. ex rel. Erica C. v. Torlakson, 762 F.3d 963, 966

(9th Cir. 2014). We reverse and remand.

Courts determine the amount in controversy for diversity jurisdiction purposes

at the time of removal, but subsequent partial dismissals may validly decrease the

amount in controversy below the jurisdictional threshold without divesting the

district court of jurisdiction. See Chavez v. JPMorgan Chase & Co., 888 F.3d 413,

417 (9th Cir. 2018). Accordingly, a district court exercising diversity jurisdiction

** The Honorable John Charles Hinderaker, United States District Judge for the District of Arizona, sitting by designation.

2 25-3650 may award fees under RCW 4.84.250 if the “amount pleaded” falls below $10,000.

Here, plaintiffs initially sought over $250,000, meaning the amount in controversy

was met upon removal. But, after the court dismissed the union plaintiffs, the

remaining Plaintiff-Appellee stated in a settlement-offer letter that her individual

damages were $10,000 or less, bringing the suit within the purview of RCW

4.84.250.

Plaintiff argues that reducing the “amount pleaded” under RCW 4.84.250

requires a plaintiff comply with the requirements for amending a complaint

contained in Federal Rule of Civil Procedure 15. But the meaning of “amount

pleaded” under RCW 4.84.250 is governed by Washington law. See Oregon Advoc.

Ctr. v. Mink, 322 F.3d 1101, 1114 n.7 (9th Cir. 2003) (applying state law to interpret

state statute); Olympic Sports Prods., Inc. v. Universal Athletic Sales Co., 760 F.2d

910, 915 (9th Cir. 1985) (“In determining the scope of [state law], we are bound by

the [State’s] interpretation of the section.”). Under Washington law, the “amount

pleaded” simply refers to notice to the opposing party that the moving party seeks

under $10,000. See Beckmann v. Spokane Transit Auth., 733 P.2d 960, 961–62

(Wash. 1987) (en banc) (finding RCW 4.84.250 “require[s] some type of notice so

that parties would realize the amount of the claim is small,” but it makes “little

sense” to require the complaint to plead RCW 4.84.250 where, in some instances,

“the complaint will not state the actual amount of damages plaintiff seeks”);

3 25-3650 Schmerer v. Darcy, 910 P.2d 498, 504 (Wash. Ct. App. 1996) (“[F]ailure to plead

an exact amount . . . will not prevent the award of attorney fees under RCW 4.84.250

if there was actual notice, prior to trial, that the claim was $10,000 or less.”). As the

district court stated, said notice “does not need to be given at the original pleading

stage and may be provided in an offer to settle or other communication at a time

before trial.” Nothing in Federal Rule of Civil Procedure 15 is inconsistent with that

meaning. Here, shortly after the district court dismissed the union plaintiffs, Plaintiff

gave notice to Defendants in a letter that she sought damages under $10,000 and

would seek attorneys’ fees under RCW 4.84.250 if she prevailed. Thus, applying

Washington law, the “amount pleaded” was under $10,000 for purposes of RCW

4.84.250, and the district court erred in finding otherwise.

Defendants also seek attorneys’ fees incurred on appeal under RCW 4.84.290.

RCW 4.84.290 provides: “if the prevailing party on appeal would be entitled to

attorneys’ fees under the provisions of RCW 4.84.250, the court deciding the appeal

shall allow to the prevailing party such additional amount as the court shall adjudge

reasonable as attorneys’ fees for the appeal.” Because this memorandum does not

ultimately determine whether Defendants are entitled to attorneys’ fees under

RCW 4.84.250, the Court cannot yet award attorneys’ fees under RCW

Guenther v. Emmons, (9th Cir. 2026).

Guenther v. Emmons (Guenther v. Emmons) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Beckmann v. Spokane Transit Authority
733 P.2d 960 (Washington Supreme Court, 1987)
Schmerer v. Darcy
910 P.2d 498 (Court of Appeals of Washington, 1996)
K.C. Ex Rel. Erica C. v. Torlakson
762 F.3d 963 (Ninth Circuit, 2014)
Elsa Chavez v. Jpmorgan Chase Bank
888 F.3d 413 (Ninth Circuit, 2018)