J.M v. Bob's Discount Furniture, LLC

CourtDistrict Court, S.D. California
DecidedMarch 24, 2025
Docket3:24-cv-01926
StatusUnknown

This text of J.M v. Bob's Discount Furniture, LLC (J.M v. Bob's Discount Furniture, LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J.M v. Bob's Discount Furniture, LLC, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 J.M. via G.A.L. RACHEL MENDOZA, Case No.: 24-cv-01926-AJB-SBC

12 Plaintiff, ORDER DENYING MOVANTS’ MOTION TO REMAND 13 v.

14 BOB’S DISCOUNT FURNITURE, LLC; (Doc. No. 28) ELEMENTS INTERNATIONAL 15 GROUP, LLC; and DOES 1 to 100, 16 inclusive,

17 Defendants.

18 BOB’S DISCOUNT FURNITURE, LLC

19 Third-Party Plaintiff, 20 v. 21

22 ELEMENTS INTERNATIONAL GROUP, LLC, and ROES 1 to 100, 23 inclusive, 24 Third-Party Defendant. 25

ELEMENTS INTERNATIONAL 26 GROUP, LLC, 27 Third-Party Plaintiff, 28 v. 1 RACHEL MENDOZA, ANGEL 2 MENDOZA, LINDA THOMAS, and 3 MOES 1 through 50, inclusive,

4 Third-Party Defendants.

5 Presently before the Court is Plaintiff/Counter-Defendant Rachel Mendoza and 6 Third-Party Defendants Angel Mendoza and Linda Thomas’ (collectively, “Movants”) 7 motion to remand. (Doc. No. 28.) Defendant/Cross-Claimant Bob’s Discount Furniture 8 (“Bob’s Discount”) filed an opposition. (Doc. No. 35.) The Court notes Movants’ reply 9 was due March 19, 2025. However, Movants have yet to file a reply. Pursuant to Civil 10 Local Rule 7.1.d.1, the Court finds the matter is suitable for determination on the papers. 11 Accordingly, the Court VACATES the hearing set for Thursday, April 10, 2025, at 2:00 12 p.m. For the reasons stated herein, the Court DENIES Movants’ motion. 13 I. BACKGROUND 14 On September 10, 2024, J.M., by and through his guardian ad litem Rachel 15 Mendoza, filed an action against Bob’s Discount in the Superior Court of California for 16 the County of San Diego, Case No. 24 CU010669C. (Doc. No. 1-2 at 2.) On October 17, 17 2024, Bob’s Discount removed this case on the basis of diversity jurisdiction. (Doc. No. 18 1.) Thereafter, on November 7, 2024, Bob’s Discount filed a third-party complaint against 19 Elements International Group (“Elements”), a Texas limited liability company. (Doc. No. 20 6.) On December 19, 2024, Movants filed a First Amended Complaint (“FAC”), adding 21 Elements as a defendant in this case. (Doc. No. 8.) On January 27, 2025, Elements filed a 22 counterclaim/third-party complaint against Movants. (Doc. No. 17.) On February 25, 2025, 23 Movants filed the instant motion to remand. (Doc. No. 28.) This Order follows. 24 II. LEGAL STANDARD 25 As courts of limited jurisdiction, federal courts may hear only those cases for which 26 subject matter jurisdiction has been conferred either by Congress or by the Constitution. 27 See Kokkonen v. Guardian Life Ins. Co., 511 U.S. 375, 377 (1994). Generally, removal of 28 1 a civil action to federal court is proper only if the district court would have original 2 jurisdiction over the matter at the time of removal. 28 U.S.C. § 1441(a). Federal courts 3 have original jurisdiction where an action presents a federal question or there is diversity 4 jurisdiction. 28 U.S.C. §§ 1331, 1332. 5 Courts have diversity jurisdiction over cases where there is complete diversity of 6 parties and the amount “in controversy exceeds the sum or value of $75,000, exclusive of 7 interest and costs.” 28 U.S.C. § 1332(a). A defendant may remove an action to federal court 8 based on diversity jurisdiction “provided that no defendant ‘is a citizen of the State in which 9 such action is brought.’” Caterpillar Inc. v. Lewis, 519 U.S. 61, 68 (1996) (quoting 28 10 U.S.C. § 1441(b)); see also Abrego Abrego v. The Dow Chem. Co., 443 F.3d 676, 679 (9th 11 Cir. 2006) (“[T]he presence in the action of a single plaintiff from the same State as a single 12 defendant deprives the district court of original diversity jurisdiction over the entire 13 action.” (citations omitted)). An individual is a citizen of the state where they are 14 domiciled, meaning the state where the individual resides and intends to remain or to which 15 the individual intends to return. Kanter v. Warner-Lambert Co., 265 F.3d 853, 857 (9th 16 Cir. 2001). 17 District courts must construe the removal statutes strictly against removal and 18 resolve any uncertainty as to removability in favor of remanding the case to state court. 19 Boggs v. Lewis, 863 F.2d 662, 663 (9th Cir. 1988). The burden is on the removing party to 20 demonstrate federal subject matter jurisdiction over the case. See Emrich v. Touche Ross 21 & Co., 846 F.2d 1190, 1195 (9th Cir. 1988). 22 III. DISCUSSION 23 Bob’s Discount’s notice of removal asserts the amount in controversy exceeds 24 $75,000 and there is complete diversity between itself and Movants. (See generally Doc. 25 No. 1.) Regarding the latter point, Bob’s Discount argues Movants are citizens of 26 California and Bob’s Discount is a limited liability company whose members are all 27 citizens of the state of Connecticut. (Id. at 2–3.) In moving to remand, Movants argue 28 complete diversity no longer exists because Elements filed a third-party complaint on 1 January 27, 2025, adding Movants as third-party defendants. (Doc. No. 28 at 1–2.) Movants 2 assert that because they are both plaintiffs and third-party defendants in this case and they 3 are from California, diversity no longer exists. (Id. at 2.) Bob’s Discount responds that 28 4 U.S.C. § 1332’s complete diversity requirement does not apply between plaintiffs and 5 third-party defendants. (Doc. No. 35 at 3 (citing Caterpillar, 519 U.S. at 66 n.1).) 6 A. Amount in Controversy 7 The parties do not dispute the amount in controversy. (See generally Doc. Nos. 1 8 (notice of removal asserting the amount in controversy to exceed $75,000); 28 (Movants’ 9 motion disputing only diversity of citizenship); 33 (Bob’s Discount’s opposition 10 reasserting that the amount exceeds $75,000).) Bob’s Discount has plausibly alleged that, 11 pursuant to Movants’ counsel’s letter demanding $4.5 million in damages, the amount in 12 controversy exceeds $75,000. (Doc. No. 1 at 3); see Dart Cherokee Basin Operating Co., 13 LLC v. Owens, 574 U.S. 81, 89 (2014) (“[A]s specified in § 1446(a), a defendant’s notice 14 of removal need include only a plausible allegation that the amount in controversy exceeds 15 the jurisdictional threshold.”). As Movants do not contest, nor does the Court see a reason 16 to question Bob’s Discount’s allegations, the Court finds Bob’s Discount has sufficiently 17 alleged the amount in controversy exceeds the required minimum threshold for diversity 18 jurisdiction. See id. at 87 (“[W]hen a defendant seeks federal-court adjudication, the 19 defendant’s amount-in-controversy allegation should be accepted when not contested by 20 the plaintiff or questioned by the court.”). 21 B. Citizenship 22 Movants argue complete diversity no longer exists due to Element’s third-party 23 complaint against Movants, who are citizens of California. (Doc. No.

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J.M v. Bob's Discount Furniture, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jm-v-bobs-discount-furniture-llc-casd-2025.