Kevin Dukes v. Sun Life Assurance Company of Canada

CourtDistrict Court, M.D. Louisiana
DecidedDecember 10, 2025
Docket3:25-cv-00623
StatusUnknown

This text of Kevin Dukes v. Sun Life Assurance Company of Canada (Kevin Dukes v. Sun Life Assurance Company of Canada) is published on Counsel Stack Legal Research, covering District Court, M.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kevin Dukes v. Sun Life Assurance Company of Canada, (M.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA KEVIN DUKES CIVIL ACTION NO. VERSUS 25-623-EWD SUN LIFE ASSURANCE COMPANY OF CANADA RULING AND ORDER! Before the Court are the following Motions: Plaintiff’s Motion to Remand to State Court;” Amended Motion to Remand, Motion for Rule 11 Sanctions, and Memorandum in Support;? Plaintiffs Motion for Rule 11(b) Sanctions and Memorandum in Support,’ all filed by Kevin Dukes (‘Plaintiff’) and Defendant Sun Life Assurance Company of Canada’s Rule 12(b)(6) Motion to Dismiss.° All motions are fully briefed and oral argument is not necessary. Because Defendant adequately established subject matter jurisdiction and there is no procedural defect in the Notice of Removal, Plaintiff’s motions will be denied. Because Plaintiff’s claims in this case are governed by the Employee Retirement Income Security Act of 1974 (“ERISA”), Defendant’s Motion to Dismiss, which seeks to dismiss any state law claims Plaintiff attempts to assert as preempted by ERISA, will be granted. To the extent pending before this Court, Plaintiff’s Motion for Summary Judgment,® filed in state court, will be denied because his state law claims are preempted by ERISA and/or fail to state claim.

' On August 4, 2025, this case was assigned to a magistrate judge for all purposes, including trial, entry of final judgment, and direct review to the United States Fifth Circuit Court of Appeals. See R. Docs. 3, 4, 10. Documents in the Court record are referred to as “R. Doc. _.” 2R. Doc. 6. 3R. Doc. 13. Doc. 15. SR. Doe. 14. Doe. 1-1, pp. 3-9.

I. BACKGROUND This case was removed to this Court from state court on July 16, 2025 by Defendant which alleged subject matter jurisdiction under 28 U.S.C. § 1331 “because plaintiff’s claim is for benefits payable under a Group Long-Term (‘LTD’) Disability Policy No. 901330 issued to Dukes’s former employer, IRISNDT Inc., which Policy was issued pursuant to an employee welfare benefit plan

governed by the Employee Retirement Income Security Act of 1974, as amended, 29 U.S.C. §1001, et seq. (‘ERISA’).”7 The Notice of Removal also alleged that diversity subject matter jurisdiction exists under 28 U.S.C. §1332, as Plaintiff is domiciled in Louisiana; Defendant is a Canadian corporation with its principal place of business in Massachusetts; and the requisite amount in controversy is established because Plaintiff expressly claims that he is entitled to $725,618.00 in damages, plus penalties and fees under La. R.S. 22:1973 and 22:1892.8 II. LAW AND ANALYSIS A. Applicable Law on Subject Matter Jurisdiction Unlike state district courts, which are courts of general jurisdiction that can hear all types

of claims, federal courts may only entertain those cases over which there is federal subject matter jurisdiction. There are two primary ways to establish federal subject matter jurisdiction. First, this Court has subject matter jurisdiction over “civil actions arising under the Constitution, laws, or treaties of the United States.”9 This Court also has subject matter jurisdiction over civil cases where the amount in controversy is more than $75,000.00, without including interest and costs, and the parties are of completely diverse citizenship (i.e., all plaintiffs are citizens of a different

7 R. Doc. 1, pp. 2-3, ¶ IX. 8 See R. Doc. 1, pp. 2, 4, ¶¶ VII, VIII, XII. 9 28 U.S.C. § 1331. state than all defendants.).10 A federal court is to presume that a case lies outside its subject matter jurisdiction, and the burden to establish federal subject matter jurisdiction is on the party asserting it (here, Defendant).11 B. Defendant Has Adequately Established Subject Matter Jurisdiction Plaintiff argues that, because he only brings claims under state law, Defendant has failed

to establish subject matter jurisdiction.12 Because of this, Plaintiff seeks remand and sanctions.13 Defendant argues that, although Plaintiff only expressly references state law claims, his claims are preempted by ERISA and any state law claims must be dismissed, such that federal question subject matter exists under 28 U.S.C. § 1331.14 Defendant alternatively argues that it has also established diversity subject matter jurisdiction under 28 U.S.C. § 1332.15 The question of subject matter jurisdiction is easily resolved, and the Court need not consider whether Defendant has adequately pleaded federal question jurisdiction to answer it because Defendant alleged sufficient facts in the Notice of Removal to establish diversity jurisdiction under 28 U.S.C. § 1332. As to diversity jurisdiction, the Notice of Removal states that

Plaintiff is domiciled in Louisiana; Defendant is a Canadian corporation with its principal place of business in the United States in Massachusetts; and the requisite amount in controversy is established because Plaintiff asserts in the Petition that he is entitled to $725,618.00 in damages, plus penalties and fees under La. R.S. 22:1973 and 22:1892.16 Plaintiff does not dispute that his

10 28 U.S.C. § 1332. 11 Mourning v. U.S. Dept. of State-Visa Office, 32 Fed.Appx. 130, at *1 (5th Cir. 2002), citing Howery v. Allstate Ins. Co., 243 F.3d 912, 916 (5th Cir. 2001), cert. denied, 534 U.S. 993 (2001). 12 R. Doc. 6, p. 2; R. Doc. 13, p. 2. 13 R. Doc. 6; R. Doc. 13; R. Doc. 15. 14 R. Doc. 11, pp. 4-5. 15 Id. at p. 8. 16 See R. Doc. 1, pp. 2, 4, ¶¶ VII, VIII, XII. Louisiana citizenship17 and the amount in controversy18 are adequately established in the Notice of Removal, but claims Defendant failed to adequately establish that “it is a non-Louisiana party for purposes of § 1332.”19 The citizenship of a corporation, which is what Defendant is alleged to be, is determined by place of incorporation and principal place of business, and both must be affirmatively alleged.20

The Notice of Removal states, as follows, regarding Defendant’s citizenship: “Defendant, Sun Life Assurance Company of Canada, is a Canadian corporation and has its principal place of business in the United States in Wellesley Hills, Massachusetts.”21 By alleging its place of incorporation and principal place of business in the United States, Defendant sufficiently alleged its own citizenship in the Notice of Removal. In his reply memorandum in support of remand on this issue, Plaintiff merely restates the test for diversity subject matter jurisdiction and then says: “Even if diversity exists, ERISA preemption cannot be used as a backdoor to remove purely state law

17 R. Doc. 6, p. 3. Although Plaintiff alleged that he is a Louisiana resident in the Motion to Remand, he alleged in the Petition that he is domiciled in Louisiana. R. Doc. 1-1, p. 1, introductory paragraph. While allegations of residency alone are not sufficient to establish subject matter jurisdiction, the Notice of Removal states that Plaintiff “is a resident of and domiciled in the Parish of East Baton Rouge, State of Louisiana.” R. Doc. 1, ¶VII (emphasis added).

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Bluebook (online)
Kevin Dukes v. Sun Life Assurance Company of Canada, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kevin-dukes-v-sun-life-assurance-company-of-canada-lamd-2025.