HealthCare Facility Management LLC v. Banayat

CourtDistrict Court, S.D. Ohio
DecidedJuly 10, 2023
Docket1:23-cv-00250
StatusUnknown

This text of HealthCare Facility Management LLC v. Banayat (HealthCare Facility Management LLC v. Banayat) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
HealthCare Facility Management LLC v. Banayat, (S.D. Ohio 2023).

Opinion

SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

HEALTHCARE FACILITY MANAGEMENT LLC, d/b/a CommuniCare Family of Companies, Case No. 1:23-cv-250

Plaintiff, Barrett, J. v. Bowman, M.J.

JEFFREY BANAYAT,

Defendant.

REPORT AND RECOMMENDATION This Report and Recommendation addresses a motion to remand currently pending before this Court. For the reasons stated, the motion to remand this case to state court should be GRANTED. I. Procedural Background Plaintiff Healthcare Facility Management LLC, doing business as CommuniCare Family of Companies (“CFC”) filed a complaint in the Hamilton County Court of Common Pleas on October 25, 2022, seeking monetary damages “in excess of $50,000.00” plus punitive damages, attorney fees, costs and interest, for breach of contract, unjust enrichment, and fraud against its former employee, Jeffrey Banayat. Plaintiff alleges that Defendant violated contractual provisions that required him to work for thirty-six months in order to pay off a debt based upon immigration costs that CFC paid on his behalf in connection with his relocation to the United States from the Republic of the Philippines. On May 1, 2023, Defendant Banayat filed a Notice of Removal in this Court. On May 31, 2023, CFC moved to remand back to state court on grounds that Defendant Banayat failed to file his Notice of Removal within thirty (30) days of ascertaining The presiding district judge has referred this case to the undersigned “to rule upon all non-dispositive pretrial motions” and “to report to the Court her recommended disposition of all dispositive pretrial motions.” (Doc. 11). In addition to the motion to remand,1 the parties have filed several non-dispositive motions: (1) Banayat’s Motion to Stay state court proceedings; (2) CFC’s motion to strike a letter filed in state court; and (3) Banayat’s motion to consolidate this case with a related case filed in this Court. See Villarin v. HealthCare Facility Management, LLC, d/b/a CommuniCare Family of Companies, Case No. 1:23-cv-97-MRB. For the following reasons, the undersigned recommends granting the motion to remand. A separate order addresses the pending

non-dispositive motions. II. Analysis A. The Notice of Removal is Untimely CFC’s motion to remand was timely filed. See 28 U.S.C. § 1447(c) (stating that a motion to remand for any defect other than subject matter jurisdiction must be filed within thirty days of the Notice of Removal). In contrast, CFC argues that Banayat’s Notice of Removal was not timely filed. Defendant Banayat has failed to file any opposition to Plaintiff’s motion, which is well-taken. The removing party bears the burden of establishing federal subject matter jurisdiction. See Smith v. Nationwide Property and Cas. Ins. Co., 505 F.3d 401, 405 (6th

Cir. 2007). Pursuant to the operative removal provision, 28 U.S.C. § 1446(b)(1), “[t]he

1A motion to remand is dispositive. See Vogel v. U.S. Office Products Co., 258 F.3d 509, 517 (6th Cir. 2001).

2 receipt by the defendant, through service or otherwise, of a copy of the initial pleading….” See generally, Murphy Bros., Inc. v. Michetti Pipe Stringing, Inc., 119 S.Ct. 1322, 1324 (1999) (statute requires receipt of complaint and service of summons in order to start the 30-day clock for removal). Only a few exceptions to the 30-day time limit exist, such as when the existence of federal jurisdiction is not apparent at the outset of the case. In that instance, 28 U.S.C. §1446(b)(3) provides: “Except as provided in subsection (c), if the case stated by the initial pleading is not removable, a notice of removal may be filed within 30 days after receipt by the defendant… of a copy of an amended pleading, motion, order or other

paper from which it may first be ascertained that the case is … removable.” In this case, CFC initiated suit in state court on October 25, 2022; Defendant acknowledged receipt of service of the complaint on November 17, 2022. (Doc. 1 at PageID 1, ¶ 1). Therefore, so long as this Court’s original jurisdiction was readily ascertainable, Banayat was required to file his Notice of Removal not later than December 17, 2022. See 28 U.S.C. § 1446(b). Instead of removing the case by that deadline, Defendant litigated the case in state court for five and a half months. He filed his answer to the complaint as well as a counterclaim on December 21, 2022, submitted a joint discovery plan, attended a case conference in state court, and briefed a motion to stay the state court proceedings. It was not until May 1, 2023 – four and a half months beyond

the expiration of the presumptive thirty-day deadline - that he filed a Notice of Removal. Defendant’s Notice of Removal cites to 28 U.S.C. § 1441 as the basis for removal. (Doc. 1 at 2, PageID 2). Under 28 U.S.C. § 1441(a), “any civil action brought in a state

3 removed by the defendant or the defendants to the district court of the United States… where such action is pending.” The Notice asserts the existence of original jurisdiction based on diversity because the parties are citizens of different states, and “the matter in controversy exceeds the sum or value of $75,000, exclusive of interests and costs.” 28 U.S.C. § 1332(a). The undersigned finds that diversity jurisdiction exists based upon the clear allegations contained in the original complaint. Asserting that his Notice “is filed within one year of the commencement of the State Court Action,” Defendant claims that it “is timely….pursuant to § 1446(c)(1).” (Doc. 1, emphasis added). Defendant is misinformed. Although § 1446(c)(1) allows up to one year

for the removal of some cases, it does not apply to this case, where it is readily ascertainable from the original pleading that the case was removable. In other words, consistent with § 1446(b)(3), 28 U.S.C. § 1446(c)(1) applies only when a case that is not initially removable later becomes removable based upon an amended pleading that includes new grounds for the exercise of diversity jurisdiction. Even then, the Notice of Removal still must be filed within thirty days of service of the amended pleading. Id.; see also 28 U.S.C. § 1446(b)(3). Here, the concurrent existence of federal jurisdiction was evident when this case was initiated. Contrary to Defendant’s belief, 28 U.S.C. § 1446(c)(1) offers no basis for extending his 30-day deadline for filing the Notice of Removal. Therefore, his Notice of

Removal was untimely and removal is improper. “Although not jurisdictional, the thirty- day period for removal is mandatory and must be strictly applied.” City of Albion v. Guaranty Nat. Ins. Co., 35 F.Supp.2d 542, 544 (W.D.Mich.1998)

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Duran v. Carris
238 F.3d 1268 (Tenth Circuit, 2001)
Lloyd G. Ellis v. State of Maine
448 F.2d 1325 (First Circuit, 1971)
United States v. Eleven Vehicles
966 F. Supp. 361 (E.D. Pennsylvania, 1997)
Smith v. Nationwide Property & Casualty Insurance
505 F.3d 401 (Sixth Circuit, 2007)
Wesley v. Don Stein Buick, Inc.
987 F. Supp. 884 (D. Kansas, 1997)
In Re Brown
354 B.R. 535 (N.D. Oklahoma, 2006)
Ostrovsky v. Monroe (In Re Ellingson)
230 B.R. 426 (D. Montana, 1999)
Johnson v. Bd. of County Com'rs County of Fremont
868 F. Supp. 1226 (D. Colorado, 1994)
City of Albion v. Guaranty National Insurance
35 F. Supp. 2d 542 (W.D. Michigan, 1998)
Vogel v. U.S. Office Products Co.
258 F.3d 509 (Sixth Circuit, 2001)

Cite This Page — Counsel Stack

Bluebook (online)
HealthCare Facility Management LLC v. Banayat, Counsel Stack Legal Research, https://law.counselstack.com/opinion/healthcare-facility-management-llc-v-banayat-ohsd-2023.