Jane Doe JAA 8000 v. Doe 1

CourtDistrict Court, C.D. California
DecidedJune 20, 2023
Docket2:23-cv-03232
StatusUnknown

This text of Jane Doe JAA 8000 v. Doe 1 (Jane Doe JAA 8000 v. Doe 1) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jane Doe JAA 8000 v. Doe 1, (C.D. Cal. 2023).

Opinion

CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES - GENERAL Case No. CV 23-3232 FMO (PVCx) Date June 20, 2023 Title Jane Doe JAA 8000 v. Doe 1, et al.

Present: The Honorable Fernando M. Olguin, United States District Judge Gabriela Garcia None None Deputy Clerk Court Reporter / Recorder Tape No. Attorney Present for Plaintiff: Attorney Present for Defendant: None Present None Present Proceedings: (In Chambers) Order Remanding Action On December 28, 2022, Jane Doe JAA 8000 (“plaintiff”) filed a Complaint in the Los Angeles Superior Court against Doe 1 (“defendant”) asserting three causes of action: (1) sexual battery in violation of California Civil Code § 1708.5; (2) sexual assault; and (3) false imprisonment. (See Dkt. 1, Defendant Doe 1's Notice of Removal (“NOR”) at ¶¶ 1-2); (id., Exhibit (“Exh.”) 3 (“Compl.”) at ¶¶ 18-39). On April 28, 2023, defendant removed that action on diversity jurisdiction grounds pursuant to 28 U.S.C. § 1332. (See Dkt. 1, NOR at ¶ 8). Having reviewed the pleadings, the court hereby remands this action to state court for lack of subject matter jurisdiction. See 28 U.S.C. § 1447(c). “Federal courts are courts of limited jurisdiction. They possess only that power authorized by Constitution and statute[.]” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377, 114 S.Ct. 1673, 1675 (1994). The courts are presumed to lack jurisdiction unless the contrary appears affirmatively from the record. See DaimlerChrysler Corp. v. Cuno, 547 U.S. 332, 342 n. 3, 126 S.Ct. 1854, 1861 n. 3 (2006). Federal courts have a duty to examine jurisdiction sua sponte before proceeding to the merits of a case, see Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574, 583, 119 S.Ct. 1563, 1569 (1999), “even in the absence of a challenge from any party.” Arbaugh v. Y&H Corp., 546 U.S. 500, 514, 126 S.Ct. 1235, 1244 (2006). “Under the plain terms of § 1441(a), in order properly to remove [an] action pursuant to that provision, [the removing defendant] must demonstrate that original subject-matter jurisdiction lies in the federal courts.” Syngenta Crop Prot., Inc. v. Henson, 537 U.S. 28, 33, 123 S.Ct. 366, 370 (2002); Abrego Abrego v. The Dow Chem. Co., 443 F.3d 676, 684 (9th Cir. 2006) (per curiam) (noting the “longstanding, near-canonical rule that the burden on removal rests with the removing defendant”); Gaus v. Miles, Inc., 980 F.2d 564, 566 (9th Cir. 1992) (“The strong presumption against removal jurisdiction means that the defendant always has the burden of establishing that removal is proper.”) (internal quotation marks omitted). If there is any doubt regarding the existence of subject matter jurisdiction, the court must resolve those doubts in favor of remanding CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES - GENERAL Case No. CV 23-3232 FMO (PVCx) Date June 20, 2023 Title Jane Doe JAA 8000 v. Doe 1, et al. the action to state court.1 See Gaus, 980 F.2d at 566 (“Federal jurisdiction must be rejected if there is any doubt as to the right of removal in the first instance.”). The court’s review of the NOR and the attached Complaint makes clear that the court does not have subject matter jurisdiction over the instant matter. In other words, plaintiff could not have originally brought this action in federal court, as plaintiff does not competently allege facts supplying diversity jurisdiction.2 Therefore, removal was improper. See 28 U.S.C. § 1441(a); Caterpillar Inc. v. Williams, 482 U.S. 386, 392, 107 S.Ct. 2425, 2429 (1987) (“Only state-court actions that originally could have been filed in federal court may be removed to federal court by the defendant.”). Defendant bears the burden of proving by a preponderance of the evidence that the amount in controversy meets the jurisdictional threshold. See Valdez v. Allstate Ins. Co., 372 F.3d 1115, 1117 (9th Cir. 2004); Matheson v. Progressive Specialty Ins. Co., 319 F.3d 1089, 1090 (9th Cir. 2003) (per curiam) (“Where it is not facially evident from the complaint that more than $75,000 is in controversy, the removing party must prove, by a preponderance of the evidence, that the amount in controversy meets the jurisdictional threshold. Where doubt regarding the right to removal exists, a case should be remanded to state court.”) (footnote omitted). Here, there is no basis for diversity jurisdiction because the amount in controversy does not appear to exceed the diversity jurisdiction threshold of $75,000. See 28 U.S.C. § 1332(a).3 As an initial matter, the amount of damages plaintiff seeks cannot be determined from the Complaint, as the Complaint does not set forth a specific amount. (See, generally, Dkt. 1-3, NOR, Exh. 3, Compl.); (Dkt. 1, NOR at ¶ 21) (“Here, the Complaint does not set forth the amount that Plaintiff seeks to recover as damages for her claims.”). However, defendant contends that the amount in controversy exceeds the jurisdictional threshold based on plaintiff’s request for relief. (See Dkt. 1, NOR at ¶ 21). But defendant has not shown that it is more likely than not that plaintiff’s request for relief would fulfill the amount in controversy requirement. (See, generally, id. ¶¶ 21-26). Defendant instead cites to plaintiff’s alleged injuries and requested forms of relief as proof, ipso facto, that the amount plaintiff seeks meets the amount in controversy requirement. 1 An “antiremoval presumption” does not exist in cases removed pursuant to the Class Action Fairness Act (“CAFA”), 28 U.S.C. § 1332(d). See Dart Cherokee Basin Operating Co., LLC v. Owens, 574 U.S. 81, 89, 135 S.Ct. 547, 554 (2014). 2 Defendant seeks only to invoke the court’s diversity jurisdiction. (See, generally, Dkt. 1, NOR). 3 In relevant part, 28 U.S.C. § 1332(a) provides that a district court has diversity jurisdiction CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES - GENERAL Case No. CV 23-3232 FMO (PVCx) Date June 20, 2023 Title Jane Doe JAA 8000 v. Doe 1, et al. (See id.). Defendant’s contention that the instant action meets the amount in controversy requirement is based, in large part, on plaintiff’s claim that “she is entitled to recover past, present and future special damages, . . . punitive damages, and statutory damages, including attorneys’ fees and pre-judgment and post-judgment interest.” (See Dkt. NOR at ¶ 21). Defendant makes no effort to estimate the amount or extent of plaintiff’s “past, present [or] future special damages.” (See, generally, id.).

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Jane Doe JAA 8000 v. Doe 1, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jane-doe-jaa-8000-v-doe-1-cacd-2023.