Janis v. United Services Automobile Association

CourtDistrict Court, E.D. Washington
DecidedOctober 28, 2024
Docket2:24-cv-00314
StatusUnknown

This text of Janis v. United Services Automobile Association (Janis v. United Services Automobile Association) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Janis v. United Services Automobile Association, (E.D. Wash. 2024).

Opinion

1 FILED IN THE U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 2 Oct 28, 2024 3 SEAN F. MCAVOY, CLERK 4 5 UNITED STATES DISTRICT COURT 6 EASTERN DISTRICT OF WASHINGTON 7 TRAVIS JANIS and MEAGAN JANIS, No. 2:24-CV-314-MKD individually and as the marital 8 community thereof, ORDER GRANTING PLAINTIFFS’ MOTION TO REMAND 9 Plaintiffs, ECF No. 5 10 v. 11 UNITED SERVICES AUTOMOBILE ASSOCIATION, a Texas interinsurance 12 exchange doing business in the State of Washington, 13 Defendant. 14

15 Before the Court is Plaintiff’s Motion to Remand. ECF No. 5. Plaintiffs are 16 represented by Ryan M. Best. Nonparty USAA Casualty Insurance Company 17 (“USAA CIC”) is represented by Anthony G. Maack and Brian R. Davis. The 18 Court has reviewed the record and is fully informed. For the reasons discussed 19 below, the Court grants the motion. 20 1 BACKGROUND 2 A. Factual Background

3 The following facts are drawn from Plaintiffs’ Complaint. ECF No. 1-1. 4 Plaintiffs are residents of Spokane County in the State of Washington. Id. at 6 ¶ 5 1.1. Defendant United Services Automobile Association (“USAA”) is a reciprocal

6 inter-insurance exchange comprised of individual members. Id. at 6 ¶ 1.2. As 7 such, USAA is a citizen of each state where it has members, including 8 Washington. Id. 9 Plaintiffs filed an insurance claim for water loss with USAA on February 15,

10 2023. Id. at 8 ¶ 2.2. Plaintiffs allege that this damage was covered under their 11 insurance policy. Id. at 8 ¶ 2.3. USAA’s initial estimate and payment for repair of 12 the damage was approximately $13,000. Id. at 8 ¶ 2.4. Plaintiffs requested a

13 certified copy of the insurance policy on April 19, 2023. Id. at 8 ¶ 2.7. USAA 14 failed to provide a certified copy of the policy as requested.1 Id. at 8 ¶ 2.8. On 15 November 17, 2023, Plaintiffs submitted a Sworn Statement in Proof of Loss for 16 $207,049.56 to USAA. Id. at 8 ¶ 2.9. USAA provided a supplemental payment for

17 repairs in the amount of $33,420.87 in January of 2023. Id. at 9 ¶ 2.11. Plaintiffs 18

19 1 A copy of the insurance policy is included as “Exhibit 2” of Defendant’s Notice of 20 Removal. ECF No. 1-2 at 1-64. 1 sent a claim communication to USAA on February 24, 2024, to which USAA 2 failed to response. Id. at 9 ¶¶ 2.12-2.13.

3 B. Procedural History 4 Plaintiffs filed suit in Spokane County Superior Court, Case No. 24-4- 5 03950-32, on August 13, 2024. ECF No. 1-1 at 5-18. Plaintiffs’ Complaint asserts

6 six causes of action: (1) violations of the Insurance Fair Conduct Act, RCW 48.30 7 et seq., RCW 19.86 et seq.; (2) Bad Faith Violations; (3) Breach of Contract; (4) 8 violations of the Consumer Protection Act; (5) Declaratory Judgement, RCW 7.24; 9 and (6) Negligent Claims Handling. Id. at 10-14.

10 Nonparty USAA Casualty Insurance Company (“USAA CIC”) filed a notice 11 of removal on September 18, 2024. ECF No. 1. The notice asserts that Plaintiffs 12 “erroneously sued” United Services Automobile Association (“USAA”) and that

13 the proper defendant is USAA CIC. Id. at 1 (emphasis in original). Plaintiffs 14 moved to remand this matter on September 23, 2024. ECF No. 5. 15 LEGAL STANDARD 16 Removal of a civil action to federal district court is proper where the federal

17 court would have original jurisdiction over the civil action. 28. U.S.C. § 1441(a); 18 Ramirez v. Fox Television Station, Inc., 998 F.2d 743, 747 (9th Cir. 1993) (citing 19 28 U.S.C. § 1441(a), (b); Jackson v. Southern California Gas Co., 881 F.2d 638,

20 641 (9th Cir. 1989)). District courts have original jurisdiction “where the matter in 1 controversy exceeds the sum or value of $75,000, exclusive of interest and costs, 2 and is between . . . citizens of different States[.]” 28 U.S.C. § 1332(a). “A

3 plaintiff who contests the existence of removal jurisdiction may file a motion to 4 remand, see 28 U.S.C. § 1447(c), the functional equivalent of a defendant’s motion 5 to dismiss for lack of subject-matter jurisdiction under Rule 12(b)(1).” Leite v.

6 Crane Co., 749 F.3d 1117, 1122 (9th Cir. 2014). 7 “[I]n a case that has been removed from state court to federal court under 28 8 U.S.C. § 1441 on the basis of diversity jurisdiction, the proponent of federal 9 jurisdiction . . . has the burden to prove, by a preponderance of the evidence, that

10 removal is proper.” Geographic Expeditions, Inc. v. Estate of Lhotka, 599 F.3d 11 1102, 1106-07 (9th Cir. 2010) (citing Gaus v. Miles, Inc., 980 F.2d 564, 567 (9th 12 Cir. 1992)). “The preponderance of the evidence standard applies because removal

13 jurisdiction ousts state-court jurisdiction and ‘must be rejected if there is any doubt 14 as to the right of removal in the first instance.’” Id. at 1107 (quoting Gaus, 980 15 F.2d at 566). Thus, courts “strictly construe the removal statute against removal 16 jurisdiction.” Gaus, 980 F.2d at 566 (citing Boggs v. Lewis, 863 F.2d 662, 663

17 (9th Cir. 1988); Takeda v. Northwestern Nat’l Life Ins. Co., 765 F.2d 815, 818 (9th 18 Cir. 1985)). 19

20 1 DISCUSSION 2 A. Subject Matter Jurisdiction

3 A federal court’s diversity jurisdiction extends “to all civil actions where the 4 matter in controversy exceeds the sum or value of $75,000, exclusive of interest 5 and costs” and the controversy “is between . . . citizens of different states.” 28

6 U.S.C. § 1332(a)(1). The diversity statute requires that each plaintiff must be a 7 citizen of a different state than the defendant. Allstate Ins. Co. v. Hughes, 358 F.3d 8 1089, 1095 (9th Cir. 2004). 9 Plaintiffs are citizens of Washington. ECF No. 1-1 at ¶ 6. Defendant USAA

10 “is a citizen of every state,” including Washington. ECF No. 5 at 4-5; see, e.g., 11 Young v. United Servs. Auto. Ass’n, 2021 WL 120968, at *2 (D. Mont. Jan. 13, 12 2021) (“USAA is considered an unincorporated association for purposes of

13 determining diversity jurisdiction. . . . USAA is therefore a citizen of each state in 14 which is [sic] has a member-subscriber.”) (citations omitted). Thus, there is not 15 complete diversity among the parties and this Court lacks subject matter 16 jurisdiction under 28 U.S.C. § 1332.

17 B. Proper Defendant 18 Nonparty USAA CIC filed the notice of removal. ECF No. 1 at 1.

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

Related

Cite This Page — Counsel Stack

Bluebook (online)
Janis v. United Services Automobile Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/janis-v-united-services-automobile-association-waed-2024.