Lee v. Safeco Insurance Company of America

CourtDistrict Court, D. Arizona
DecidedJuly 1, 2022
Docket2:22-cv-00527
StatusUnknown

This text of Lee v. Safeco Insurance Company of America (Lee v. Safeco Insurance Company of America) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lee v. Safeco Insurance Company of America, (D. Ariz. 2022).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8

Ronald Lee, et al., ) No. CV-22-00527-PHX-SPL ) 9 ) 10 Plaintiffs, ) ORDER vs. ) ) 11 ) Safeco Insurance Company of ) 12 America, ) 13 ) ) Defendant. ) 14 ) 15 Before the Court is Plaintiffs’ Motion to Remand (Doc. 7). For the following 16 reasons, the Court will grant the Motion and remand to state court. 17 I. BACKGROUND 18 Plaintiffs Ronald and Tamara Lee had a homeowners insurance policy with 19 Defendant Safeco Insurance Company of America. (Doc. 11 at 1). On February 23, 2022, 20 Plaintiffs filed suit against Defendant in Gila County Superior Court alleging breach of 21 contract and breach of the implied covenant of good faith and fair dealing. (Id. at 1–2). 22 This action arose from a denied insurance claim related to water damage to Plaintiffs’ 23 property. (Id.). Plaintiffs seek roughly $50,000 in property damages, plus alternative living 24 expenses, attorneys’ fees, and unspecified amounts for bad faith and punitive damages. 25 (Doc. 1–3 at 7; Doc. 7 at 2–3). 26 On April 1, 2022, Defendant removed this action pursuant to 28 U.S.C. § 1446, 27 claiming diversity jurisdiction under 28 U.S.C. § 1332. (Doc. 1 at 1, 3). Plaintiffs now 28 1 move to remand this action to the Arizona Superior Court for lack of subject matter 2 jurisdiction. (Doc. 7 at 1). 3 II. LEGAL STANDARD 4 Federal courts may exercise removal jurisdiction over a case only if subject-matter 5 jurisdiction exists. 28 U.S.C. § 1441(a); Valdez v. Allstate Ins. Co., 372 F.3d 1115, 1116– 6 17 (9th Cir. 2004). The removing party bears the burden of establishing subject-matter 7 jurisdiction as a basis for removal by a preponderance of the evidence. Id. at 1117; Emrich 8 v. Touche Ross & Co., 846 F.2d 1190, 1195 (9th Cir. 1988). To satisfy this burden under 9 28 U.S.C. § 1441, the removing party must demonstrate that jurisdiction existed at the time 10 of removal. Hunter v. Philip Morris USA, 582 F.3d 1039, 1042 (9th Cir. 2009). There is a 11 “strong presumption against removal jurisdiction,” and such jurisdiction “must be rejected 12 if there is any doubt as to the right of removal in the first instance.” Geographic 13 Expeditions, Inc. v. Est. of Lhotka ex rel. Lhotka, 599 F.3d 1102, 1107 (9th Cir. 2010) 14 (internal quotation marks and citation omitted). 15 Diversity jurisdiction exists when the amount in controversy exceeds $75,000 and 16 the case is between citizens of different states. See 28 U.S.C. § 1332(a). In a situation where 17 the amount in controversy is unclear from the face of a state-court complaint, “[t]he 18 removing defendant bears the burden of establishing, by a preponderance of the evidence, 19 that the amount in controversy exceeds the jurisdictional amount” by providing “evidence 20 establishing that it is ‘more likely than not’ that the amount in controversy exceeds that 21 amount.” Sanchez v. Monumental Life Ins. Co., 102 F.3d 398, 403–04 (9th Cir. 1996). The 22 amount in controversy is “the amount at stake in the underlying litigation,” including 23 compensatory damages, punitive damages, and attorneys’ fees awards under fee-shifting 24 statutes, but excluding interests and costs. Gonzales v. CarMax Auto Superstores, LLC, 25 840 F.3d 644, 648–49 (9th Cir. 2016). A court may look outside the face of the complaint 26 to determine the amount in controversy when it is not stated with specificity in the 27 complaint. Valdez, 372 F.3d at 1117. This means that courts may consider allegations made 28 in the notice of removal as well as “summary-judgment-type evidence.” Id. (internal 1 quotation marks omitted). 2 III. DISCUSSION 3 The parties do not dispute that diversity exists, so only issue is whether the amount- 4 in-controversy requirement of 28 U.S.C. § 1332(a) is met. Plaintiffs argue that this case 5 must be remanded to the Gila County Superior Court because the amount in controversy is 6 not expected to exceed $75,000. (Doc. 7 at 2). Specifically, Plaintiffs argue that the amount 7 at issue includes approximately $50,000 in property damages, plus “unspecified amounts 8 for bad faith and punitive damages.” (Id.). In response, Defendant offers four pieces of 9 evidence to demonstrate that Plaintiffs’ claims exceed the jurisdictional amount: (1) at 10 minimum, Plaintiffs’ contract damages are $51,615.38 due to Plaintiffs’ alternative living 11 expenses; (2) other courts in this District have declined to remand similar cases; 12 (3) Plaintiffs designated this case as “Tier 2” pursuant to Ariz. R. Civ. P. 26.2 upon filing 13 in state court; and (4) Plaintiffs’ attorneys’ fees, added to the other requested relief, will 14 result in an award that exceeds $75,000. (Id. at 5–9). 15 A. Minimum Contract Damages 16 This Court finds Defendant’s first piece of evidence—regarding Plaintiffs’ 17 alternative living expenses—to carry little weight. Defendant estimates Plaintiffs’ 18 alternative living expenses, as calculated according to the Additional Living Expense 19 coverage of their insurance policy, will be at least $1,615.38. (Id. at 5). Defendant argues 20 that because Plaintiffs’ Motion does not dispute Defendant’s calculation, Plaintiffs concede 21 that their contract damages are, at a minimum, $51,615.38. (Id.). This calculation is some 22 evidence of the amount of contract damages at issue, insofar as it shows the amount in 23 controversy may be at least $51,615.38. This amount, however, still fails to meet the 24 $75,000 threshold. 25 B. Similar Cases 26 Defendant argues that courts in this District have found the amount in controversy 27 requirement was met in similar cases. (Doc. 11 at 6). This Court finds that Defendant has 28 failed to show evidence or point to any analogous cases suggesting the amount in 1 controversy meets the jurisdictional requirement. 2 Upon review, the Court finds Defendant’s citations to Haller v. Auto-Owners Ins. 3 Co., No. CV-20-01606-PHX-GMS, 2021 WL 3732763 (D. Ariz. Aug. 24, 2021), and 4 Treon v. Aetna Life Ins. Co., No. CV-20-00529-PHX-JJT, 2020 WL 2537484 (D. Ariz. 5 May 19, 2020), to be unpersuasive. In Haller, the plaintiffs had not demanded a dollar 6 amount in their complaint, sought a contracts award that could be in excess of $64,000, 7 asserted a tort of bad faith claim, and initially demanded more than $75,000 in mediation. 8 Haller, 2021 WL 3732763, at *3. Distinguishably, in the case at hand, Plaintiffs’ 9 Complaint seeks approximately $50,000 in contract damages, an estimated $1,615.38 in 10 additional living expenses, and an unspecified amount of damages pursuant to their tort of 11 bad faith claim. (Doc. 1-3 at 7).

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Lee v. Safeco Insurance Company of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lee-v-safeco-insurance-company-of-america-azd-2022.