Hollins v. Staffa

CourtDistrict Court, W.D. Texas
DecidedNovember 17, 2023
Docket5:23-cv-01083
StatusUnknown

This text of Hollins v. Staffa (Hollins v. Staffa) is published on Counsel Stack Legal Research, covering District Court, W.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hollins v. Staffa, (W.D. Tex. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

LARRY EUGENE HOLLINS, § Plaintiff § § SA-23-CV-01083-XR -vs- § § AUDREY STAFFA, CARLOS OMAR § CHAVEZ JR., § Defendants §

ORDER On this date, the Court considered Plaintiff’s motion for remand (ECF No. 6). After careful consideration, Plaintiff’s motion for remand is GRANTED. BACKGROUND Plaintiff Larry Hollins alleges that he and his brother, Leon Hollins (“Leon”), were involved in a three-car collision with Defendants Audrey Staffa (“Staffa”) and Carlos Omar Chavez, Jr. (“Chavez”) on the I-10 highway in Texas. ECF No. 1–2 at 2. On May 31, 2021, Staffa “collided with the vehicle immediately in front of her operated by [Chavez],” pushing Defendant Chavez’s car into the vehicle driven by Leon, in which Plaintiff was a passenger. Id. at 2–3. The force of this collision propelled Plaintiff’s vehicle into a nearby median. Id. Plaintiff asserts that Staffa caused the crash because she “failed to control her speed, failed to maintain a safe distance, and failed to apply her brakes on time.” Id. at 3. Plaintiff also alleges that Chavez contributed to the crash because he “failed to keep a proper lookout, failed to control his speed, and suddenly stopped on the highway.” Id. On April 3, 2023, Plaintiff and Leon filed suit against Staffa and Chavez in the 224th Judicial District Court in Bexar County, Texas, asserting claims for negligence and negligence per se. Id. at 1, 3. Plaintiff pursued claims against both Staffa and Chavez; Leon pursued claims against Chavez, which he later non-suited in state court. See ECF No. 1-2; ECF No. 1-5. On April 17, 2023, Staffa was personally served at her home in Williamson County, Tennessee.1 ECF No. 6-1. Plaintiff and Leon initially believed that Chavez was served on April

18, 2023, at his home in Bexar County, Texas. ECF No. 6 at 3; ECF No. 6-7 at 1. However, they later discovered that Defendant Chavez’s father had been served the petition in error, and Plaintiff successfully served Chavez on September 12, 2023, at a correctional facility in Limestone County, Texas. ECF No. 6 at 3; ECF No. 7 at 2. On August 29, 2023, Staffa removed the case to this Court based on diversity jurisdiction. ECF No. 1 at 1. Plaintiff subsequently filed a motion to remand, asserting that there is not complete diversity of citizenship because Plaintiff and Defendant Chavez are both residents of Texas. ECF No. 6. Defendant has not filed a response and the time in which to do so has expired. LEGAL STANDARDS Federal district courts have original jurisdiction “over two general types of cases: cases

that arise under federal law . . . and cases in which the amount in controversy exceeds $75,000 and there is diversity of citizenship among the parties.” Home Depot U. S. A., Inc. v. Jackson, 139 S. Ct. 1743, 1746 (2019) (citing 28 U.S.C. §§ 1331, 1332(a)). The former is known as “federal- question jurisdiction” and the latter as “diversity jurisdiction.” Id. Any civil action of these types that is brought in state court “may be removed by the defendant or the defendants, to the district court of the United States for the district and division embracing the place where such action is pending.” 28 U.S.C. § 1441(a).

1 Although the petition describes Staffa as a resident of Bexar County, Texas, the parties agree that Staffa is domiciled in Tennessee. ECF No. 1 at 2; ECF No. 6 at 2. On a motion to remand, a court must consider whether removal to federal court was proper. Removal is proper in any “civil action brought in a State court of which the district courts of the United States have original jurisdiction.” Id. The removing party bears the burden of showing that federal jurisdiction exists and that removal was proper. De Aguilar v. Boeing Co., 47 F.3d 1404,

1408 (5th Cir. 1995). The removal statute is strictly construed in favor of remand. Vantage Drilling Co. v. Hsin-Chi Su, 741 F.3d 535, 537 (5th Cir. 2014) (citing Acuna v. Brown & Root, Inc., 200 F.3d 335, 339 (5th Cir. 2000)). The Court must resolve “all factual allegations,” “all contested issues of substantive fact,” and “all ambiguities in the controlling state law” in the plaintiff’s favor. Guillory v. PPG Indus., Inc., 434 F.3d 303, 308 (5th Cir. 2005). In other words, “any doubt about the propriety of removal must be resolved in favor of remand.” Gasch v. Hartford Acc. & Indem. Co., 491 F.3d 278, 281–82 (5th Cir. 2007). The court must evaluate the removing party’s right to remove “according to the plaintiffs’ pleading at the time of the petition for removal.” Pullman Co. v. Jenkins, 305 U.S. 534, 537 (1939); see also Gebbia v. Wal-Mart Stores, Inc., 233 F.3d 880, 883 (5th Cir. 2000) (“The jurisdictional

facts that support removal must be judged at the time of removal.”); Martinez v. Pfizer Inc., 388 F. Supp. 3d 748, 761 (W.D. Tex. 2019) (“[B]ecause jurisdiction is fixed at the time of removal, the jurisdictional facts supporting removal are examined as of the time of removal.”). A removing party can establish federal jurisdiction based on 28 U.S.C. § 1332 by demonstrating that an in-state defendant has been “improperly joined.” Smallwood v. Ill. Cent. R. Co., 385 F.3d 568, 573 (5th Cir. 2004) (en banc). The burden is on the removing party, and the burden of demonstrating improper joinder is a heavy one. Cuevas v. BAC Home Loans Servicing, LP, 648 F.3d 242, 249 (5th Cir. 2011). To establish improper joinder, a removing party must show “(1) actual fraud in the pleading of jurisdictional facts, or (2) inability of the plaintiff to establish a cause of action against the non-diverse party in state court.” Smallwood, at 385 F.3d at 573. DISCUSSION The Court concludes that it cannot exercise subject matter jurisdiction in this matter

because the opposing parties lack complete diversity. Both Plaintiff Leon Hollins and Defendant Chavez are residents of Texas, thereby destroying complete diversity. Harvey v. Grey Wolf Drilling Co., 542 F.3d 1077, 1079 (5th Cir. 2008) (“Complete diversity requires that all persons on one side of the controversy be citizens of different states than all persons on the other side.”) (citation omitted). Staffa attempts to overcome this fatal problem for removal by asserting “outright fraud in Plaintiffs’ pleading of jurisdictional facts,” alleging that Plaintiff improperly joined Chavez solely to defeat diversity jurisdiction. ECF No. 1 at 2.

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Related

De Aguilar v. Boeing Co.
47 F.3d 1404 (Fifth Circuit, 1995)
Acuna v. Brown & Root Inc.
200 F.3d 335 (Fifth Circuit, 2000)
Gebbia v. Wal-Mart Stores, Inc.
233 F.3d 880 (Fifth Circuit, 2000)
Travis v. Irby
326 F.3d 644 (Fifth Circuit, 2003)
Guillory v. PPG Industries, Inc.
434 F.3d 303 (Fifth Circuit, 2005)
Harvey v. Grey Wolf Drilling Co.
542 F.3d 1077 (Fifth Circuit, 2008)
Pullman Co. v. Jenkins
305 U.S. 534 (Supreme Court, 1939)
Cuevas v. BAC Home Loans Servicing, LP
648 F.3d 242 (Fifth Circuit, 2011)
Vantage Drilling Company v. Hsin-Chi Su
741 F.3d 535 (Fifth Circuit, 2014)
Thompson v. Deutsche Bank National Trust Co.
775 F.3d 298 (Fifth Circuit, 2014)
Home Depot U. S. A., Inc. v. Jackson
587 U.S. 435 (Supreme Court, 2019)
Martinez v. Pfizer Inc.
388 F. Supp. 3d 748 (W.D. Texas, 2019)
Coffman v. Dole Fresh Fruit Co.
927 F. Supp. 2d 427 (E.D. Texas, 2013)

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Hollins v. Staffa, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hollins-v-staffa-txwd-2023.