Juan Carlos Galindo Garcia v. Walmart Inc.

CourtDistrict Court, C.D. California
DecidedMarch 16, 2022
Docket2:22-cv-00371
StatusUnknown

This text of Juan Carlos Galindo Garcia v. Walmart Inc. (Juan Carlos Galindo Garcia v. Walmart 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
Juan Carlos Galindo Garcia v. Walmart Inc., (C.D. Cal. 2022).

Opinion

Case 2:22-cv-00371-SVW-MRW Document 20 Filed 03/16/22 Page1of5 Page ID #:467 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES —- GENERAL Case No. 2:22-cv-00371-SVW-MRW Date March 16, 2022

Title Juan Carlos Galindo Garcia v. Walmart, Inc. et al.

Present: The Honorable STEPHEN V. WILSON, U.S. DISTRICT JUDGE Paul M. Cruz N/A Deputy Clerk Court Reporter / Recorder Attorneys Present for Plaintiff: Attorneys Present for Defendant: N/A N/A Proceedings: ORDER DENYING MOTION TO REMAND [8] Before the Court is Plaintiff Juan Carlos Galindo Garcia’s (“Plaintiff”) motion to remand. See ECF No. 8. Plaintiff brings this slip and fall action against Defendant Walmart, Inc. (“Walmart’’), Doe 1 Manager, Doe 2 Employee and Does 3 through 50. See Compl. §§ 1-7, Ex. 1 to Not. Removal, ECF No. 1-1. Walmart removed the action to this Court on the basis of diversity jurisdiction. See Not. Removal § 7, ECF No. 1; see 28 U.S.C. § 1332, § 1441(b). Plaintiff is a citizen of the state of California, and Walmart is a Delaware corporation with its principal place of business in Bentonville, Arkansas. Jd. at §§ 10,14. uncontroverted that there is complete diversity between Plaintiff and Walmart. Nevertheless, Plaintiff contends that the Court must remand this action because Plaintiff's allegations as to the Doe Defendants destroy complete diversity.! See Mot. at 1. Specifically, Plaintiff avers that “Doe 1 Manager” and “Doe 2 Employee” are residents of California—rendering the parties non-diverse. Compl. §j 3-4.

1 Separately, Plaintiff argues that Walmart’s notice of removal fails to satisfy the $75,000 amount in controversy threshold necessary for diversity jurisdiction. However, Walmart included with its notice of removal a Request for Admission it served upon Plaintiff and Plaintiff's subsequent response—in which Plaintiff explicitly admitted that he seeks damages in excess of $75,000. See Plaintiff's Response to Defendant’s Request for Admission at p. 92, No. 36, ECF No. 1-7. Thus, the jurisdictional threshold is satisfied, and Plaintiff's argument is unavailing.

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Case 2:22-cv-00371-SVW-MRW Document 20 Filed 03/16/22 Page2of5 Page ID #:468 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES —- GENERAL Case No. 2:22-cv-00371-SVW-MRW Date March 16, 2022

Title Juan Carlos Galindo Garcia v. Walmart, Inc. et al. Whether such allegations are sufficient to destroy complete diversity—requiring remand—is a question other courts have deemed “convoluted and unsettled.” Johnson v. Starbucks Corp., 475 F. Supp. 3d 1080, 1083 (C.D. Cal. 2020); Goldsmith v. CVS Pharmacy, Inc., No. CV 20-00750-AB (JCX), 2020 WL 1650750, at *4 (C.D. Cal. Apr. 3, 2020); Robinson v. Lowe’s Home Centers, LLC, No. 1:15- cv-1321-LJO-SMS, 2015 WL 13236883, at *3 (E.D. Cal. Nov. 13, 2015). The issue arises from two divergent lines of authority. The first is based on the Judicial Improvements and Access to Justice Act, which Congress passed in 1998. See Goldsmith, 2020 WL 160750, at *3. This Act amended the removal statute, 28 U.S.C. § 1441, to address “the issue of Doe defendants for purposes of diversity jurisdiction and remand.” /d.; see also Gardiner Family, LLC v. Crimson Res. Mgmt. Corp., 147 F. Supp. 3d 1029, 1034, 1036 (E.D. Cal. 2015) (discussing the amendment and its consequences in the context of a diversity case originally filed in federal court). Today, 28 U.S.C. § 1441(b)(1) states that, when jurisdiction is based solely on diversity, “the citizenship of defendants sued under fictitious names shall be disregarded.” See 28 U.S.C. § 1441(b)(1); Johnson, 475 F. Supp. 3d at 1083. The Ninth Circuit has explicitly held that “[t]he citizenship of fictitious defendants is disregarded for removal purposes and becomes relevant only if and when the plaintiff seeks leave to substitute a named defendant.” Soliman v. Philip Morris Inc., 311 F.3d 966, 971 (9th Cir. 2002). Pursuant to the plain language of the statute and relevant case law, this Court cannot consider the citizenship of Doe Manager and Doe Employee until Plaintiff seeks leave to substitute a named defendant. See id.; Goldsmith, 2020 WL 160750, at *3; Rojas by & through Rojas v. Sea World Parks & Ent., Inc., 538 F. Supp. 3d 1008, 1023 (S.D. Cal. 2021) (“[N]ot only is the plain language of Section 1441(b) clear in mandating that courts should disregard the citizenship of fictious defendants when evaluating whether diversity jurisdiction exists on a motion to remand, but the legislative history corroborates and confirms this conclusion.”’). On this basis, the Court denies Plaintiff's motion. Nevertheless, other courts look beyond the language of 28 U.S.C. § 1441(b)(1) by distinguishing between “fictitious” and “real” Does. These courts assess whether the “[p]laintiffs’ description of Doe defendants or their activities is specific enough as to suggest their identity, citizenship, or relationship to

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Case 2:22-cv-00371-SVW-MRW Document 20 Filed 03/16/22 Page 3of5 Page ID #:469 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES — GENERAL Case No. 2:22-cv-00371-SVW-MRW Date March 16, 2022

Title Juan Carlos Galindo Garcia v. Walmart, Inc. et al. the action.” Jolmson, 475 F. Supp. 3d at 1083 (citing Gardiner Family, 147 F. Supp. 3d at 1036; Sandoval v. Republic Servs., Inc., No. 18-cv-01224-ODW (KSx), 2018 WL 1989528, at *3—4 (C.D. Cal. Apr. 24, 2018) (“[W]Jhen a plaintiffs allegations give a definite clue about the identity of the fictitious defendant. ..the court should consider the citizenship of the fictitious defendant.”’)). As a preliminary matter, this Court is skeptical of the need to conduct this further inquiry. Many of the courts that do so rely on the reasoning in Gardiner, 147 F. Supp. 3d at 1030, but fail to consider Gardiner’s distinct procedural posture. See, e.g., Johnson, 475 F. Supp. 3d at 1083-84; Barnes v. Costco Wholesale Corp., No. CV197977DMGJPRX, 2019 WL 6608735, at *2 (C.D. Cal. Dec. 4, 2019); Rodas v. Costco Wholesale Corp., No. CV217183DMGGJSX, 2021 WL 5233526, at *1 (C.D. Cal. Nov. 10, 2021); Sandoval, 2018 WL 1989528, at *3. Specifically, in Gardiner, however, the court discussed whether the presence of Doe defendants in a diversity case originally filed in federal court destroys diversity. See id. Because Gardiner was not a removal case, the court did not evaluate the preclusive effect of the language in 28 U.S.C. § 1441(b)(1). See id. Thus, because the various cases that extend Gardiner to the removal context gloss over the clear language in § 1441(b)(1) and subsequent case law like Solimon, 311 F.3d at 971, the Court does not find them persuasive.

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Related

Martin v. Franklin Capital Corp.
546 U.S. 132 (Supreme Court, 2005)
Soliman v. Philip Morris Incorporated
311 F.3d 966 (Ninth Circuit, 2002)
Gardiner Family, LLC v. Crimson Resource Management Corp.
147 F. Supp. 3d 1029 (E.D. California, 2015)

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Juan Carlos Galindo Garcia v. Walmart Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/juan-carlos-galindo-garcia-v-walmart-inc-cacd-2022.