Janet Hill v. Nexstar Media Inc.

CourtDistrict Court, C.D. California
DecidedOctober 17, 2023
Docket2:23-cv-05617
StatusUnknown

This text of Janet Hill v. Nexstar Media Inc. (Janet Hill v. Nexstar Media Inc.) 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
Janet Hill v. Nexstar Media Inc., (C.D. Cal. 2023).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA J S-6 CIVIL MINUTES - GENERAL CaseNo. 2:23-cv-05617-SVW-IC Date October 17, 2023

Janet Hill v. Nexstar Media Inc. et al Title

Present: The Honorable STEPHEN V. WILSON, U.S. DISTRICT JUDGE Paul M. Cruz N/A Deputy Clerk Court Reporter / Recorder Attorneys Present for Plaintiffs: Attorneys Present for Defendants: N/A N/A Proceedings: ORDER GRANTING PLAINTIFF’s MOTION FOR REMAND [13] I. Introduction Before the Court is a motion to remand the action back to state court. Dkt. 13. For the following reasons, the motion is GRANTED. IL. Factual and Procedural Background Plaintiff Janet Hill (“Plaintiff”) filed this lawsuit against defendants Nexstar Media Inc. (“Nexstar”) and Jason Ball in Los Angeles Superior Court on May 27, 2020. Dkt. 1, Ex. A. Plaintiff worked at Nexstar for approximately 29 years. Jd. § 14. Ball was Plaintiff's direct supervisor from 2008 to 2021. Id. 16, 29. Plaintiff alleged seven causes of action against Nexstar related to employment discrimination, retaliation, and harassment. Jd. J] 41-98. Plaintiff alleged two causes of action against Ball: harassment in violation of California Government Code §12940(j)(1), et seq., and intentional infliction of emotional distress. Jd. 59-68, 92-98. Defendants removed the case on July 12, 2023. Dkt. 1. Plaintiff filed this motion to remand on August 9, 2023. Dkt. 13. Nexstar is a citizen of Delaware and Texas. Dkt. 15 at 1. It is undisputed that Plaintiff and Ball are both citizens of California. Dkt. 13 at 8; Dkt. 15 at 1. Nevertheless, defendants argue that removal is proper based on diversity jurisdiction because Ball is a sham defendant who must be dismissed. Dkt. 1, { 17. Ill. Legal Standard

Initials of Preparer PMC

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES - GENERAL Case No. 2:23-cv-05617-SVW-JC Date October 17, 2023

Federal courts are courts of limited jurisdiction and have subject matter jurisdiction only where authorized by the Constitution and Congress. See Kokkonen v. Guardian Life Ins. Co., 511 U.S. 375, 377 (1994). A suit filed in state court may be removed to federal court if the federal court would have had original jurisdiction over the suit. 28 U.S.C. § 1441(a). Federal courts have original jurisdiction where an action arises under federal law or where each plaintiff's citizenship is diverse from each defendant's citizenship and the amount in controversy exceeds $75,000. §§ 1331, 1332(a). The removing defendant bears the burden of establishing original jurisdiction. See Syngenta Crop Prot., Inc. v. Henson, 537 U.S. 28, 33 (2002). Failure to do so requires that the case be remanded, as “s]ubject matter jurisdiction may not be waived, and ... the district court must remand if it lacks jurisdiction.” Kelton Arms Condo. Owners Ass'n v. Homestead Ins. Co., 346 F.3d 1190, 1192 (9th Cir. 2003). IV. Analysis Here, the parties are not completely diverse. Plaintiff and Ball are both citizens of California. Dkt. 13 at 8; Dkt. 15 at 1. However, defendants argue that Ball was fraudulently joined to defeat diversity jurisdiction because the harassment and intentional infliction of emotional distress claims against him are “deficient.” Dkt. 1, 25. A defendant’s citizenship should be disregarded for purposes of diversity jurisdiction when the defendant “cannot be liable on any theory.” Grancare, LLC v. Thrower by and through Mills, 889 F.3d 543, 548 (9th Cir. 2018) (internal citation omitted). “If there is a possibility that a state court would find that the complaint states a cause of action against any of the resident defendants, the federal court must find that the jomder was proper and remand the case to the state court.” Jd. (internal citation omitted) (italics in original). The defendant bears a “heavy burden” to overcome the “general presumption against [finding] fraudulent joinder.” Jd. (quoting Gaus, 980 F.2d at 566). Defendant has not met this burden. Plaintiff has shown that Ball can be liable for harassment, which is sufficient for remand. The California Fair Employment Housing Act (FEHA) prohibits harassment of an employee. Cal. Gov't Code § 12940(j)(1). To establish a claim for harassment, a plaintiff must demonstrate that: (1) she is a member of a protected group; (2) she was subjected to harassment because she belonged to this group; and (3) the alleged harassment was so severe that it created a hostile work environment. Law/er

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES - GENERAL Case No. 2:23-cv-05617-SVW-JC Date October 17, 2023

Ti Janet Hill v. Nexstar Media Inc. et al itle

v. Montblanc N. Am., LLC, 704 F.3d 1235, 1244 (9th Cir. 2013). Harassment constitutes conduct outside the scope of necessary job performance, presumably engaged in for personal gratification, because of meanness or bigotry, or for other personal motives. Landucci v. State Farm Ins. Co., 65 F. Supp. 3d 694, 705 (N.D. Cal. 2014). Employees are personally liable for their own harassing behavior. McClung v. Emp. Dev. Dep't, 34 Cal. 4th 467, 471 (2004): Cal. Gov't Code § 12940(j)(3). Additionally, harassment is unlawful if supervisors know or should know of the conduct and fail to take immediate and appropriate corrective action. Cal. Gov't Code § 12940(;)(1). However, harassment does not include the type of conduct necessary to manage an employer's business or perform a supervisory role. Landucci, 65 F. Supp. 3d at 705. For example, harassment does not include common and necessary personnel management actions such as hiring and firing, job or project assignments, promotion and demotion, and performance evaluations. Law/er 704 F.3d at 1244. Additionally, an employee cannot recover for harassment that is occasional, isolated, sporadic, or trivial. Id. at 1245. Rather, the plaintiff must show a concerted pattern of harassment of a repeated, routine, or generalized nature. Jd. at 1244. Defendants have not met their heavy burden to show that there is no possibility that a state court would find that the complaint states a cause of action for harassment against Ball. Plaintiff alleges that Ball would unnecessarily raise his voice and scream at her during meetings, belittling and embarrassing her in front of colleagues. Dkt. 1, Ex. A, § 25. Plaintiff alleges she was denied opportunities to meet one- on-one with her supervisor when every other person in her position was afforded these meetings. Jd. § 23. These allegations are sufficient to demonstrate repeated conduct that fell outside the scope of necessary job performance. See Landucci, 65 F. Supp. 3d at 705. Additionally, Plaintiff alleges several isolated incidents that, when combined with these repeated behaviors, could sufficiently allege a hostile work environment. For example, Plaintiff alleges that Ball made racially charged comments, including negative feedback about Plaintiff wearing her hair naturally instead of flat ironing it. Dkt. 1, Ex. A, □ 24. Further, Plaintiffs allegations are sufficient to infer that Ball, as Plaintiffs direct supervisor, may have failed to investigate incidents of racial harassment and sexual harassment. See id. {J 18-20, 62.

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Related

Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Syngenta Crop Protection, Inc. v. Henson
537 U.S. 28 (Supreme Court, 2002)
Cynthia Lawler v. Montblanc North America, LLC
704 F.3d 1235 (Ninth Circuit, 2013)
McClung v. Employment Development Department
99 P.3d 1015 (California Supreme Court, 2004)
Grancare v. Ruth Thrower
889 F.3d 543 (Ninth Circuit, 2018)
Landucci v. State Farm Insurance
65 F. Supp. 3d 694 (N.D. California, 2014)

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Bluebook (online)
Janet Hill v. Nexstar Media Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/janet-hill-v-nexstar-media-inc-cacd-2023.