Lizama v. Michaels Stores, Inc.

CourtDistrict Court, E.D. Missouri
DecidedApril 29, 2022
Docket4:21-cv-01133
StatusUnknown

This text of Lizama v. Michaels Stores, Inc. (Lizama v. Michaels Stores, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lizama v. Michaels Stores, Inc., (E.D. Mo. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

ABRAHAM LIZAMA, ) ) Plaintiff, ) ) v. ) Case No. 4:21-cv-01133-HEA ) MICHAELS STORES, INC., ) ) Defendant. )

OPINION, MEMORANDUM AND ORDER

This matter is before the Court on Plaintiff’s Motion to Remand, [Doc. No. 19]. Defendant opposes the Motion and has filed a Memorandum in Opposition. For the reasons set forth below, the Motion will be granted. Facts and Background This is a putative class action filed by Plaintiff in the Circuit Court of St. Louis County, Missouri on behalf of himself and all persons and entities who purchased a product from Defendant through remote sales channels, including its internet website, that was delivered from an out-of-state facility to a Missouri delivery address and who were allegedly charged tax monies at a higher tax rate than the correct applicable use tax rate. According to the Petition, Missouri law requires retailers to charge sales or use tax on the sales of their products to Missouri purchasers. Missouri state law mandates that retailers with a tax nexus charge a use tax on sales of their products through remote means, including an internet website, telephone, catalog, or other

remote communications systems (collectively, “remote sales channel(s)”) to Missouri purchasers that are shipped from an out-of-state facility. The state use tax rate for these sales is 4.225%.

The Petition also claims there may be additional local use taxes that are imposed on sales made through remote sales channels based on the delivery address of the Missouri purchasers. The state use tax rate of 4.225% plus any applicable local use tax impositions is the cumulative use tax rate for any given

location. Plaintiff seeks to represent all similarly situated persons, damages for the overcollection of excess tax, and injunctive relief. Plaintiff seeks damages and

costs for violations of the Missouri Merchandising Practices Act (“MMPA”), Mo Rev. Stat. § 407.010 et seq., and damages for unjust enrichment, negligence, and money had and received. Defendant removed the case from the Circuit Court of St. Louis County on

September 17, 2021. Defendant asserts original jurisdiction pursuant to the Class Action Fairness Act (“CAFA”), 28 U.S.C. 1332(d). The CAFA authorizes removal if there is minimal diversity, the amount in controversy exceeds $5 million in the

aggregate, and the proposed class contains at least 100 members. Defendant based the removal on the following: $723,680.00 in estimated actual damages, which it claims represents the amount of excess taxes it over-

collected during the class period; a 33% attorney fee award of the estimated actual damages which would be $241,226.67; injunctive relief based on the taxes that Michaels would annually cease over-collecting, which equals a discounted

$1,161,544.21 over the next 10 years and $1,857,003.63 over the next 20 years; and a “conservative estimation” of punitive damages at a ratio of 4:1 which would be $2,894,720.00 and a 27:1 ratio of $19,539,360.00. Plaintiff disputes the basis for removal in part and adjusts as follows:

$723,680.00 in estimated actual damages; a 33% attorney fee award of the estimated actual damages which would be $241,226.67; and, assuming arguendo, that Defendant is permitted to include the most extreme calculation of prospective

injunctive relief in taxes that it would cease to collect (i.e., $1,857,003.63) in its calculation of the amount in controversy, the maximum amount of controversy in this case is about $2,821,910.30 ($723,680.00 + $241,226.67 + the 20-year, 5% discounted value of $1,857,003.63). Plaintiff maintains that this is substantially

below the CAFA threshold. In its Memorandum in Opposition, Defendant re-calculated the basis for removal and is as follows: $542,760.00 in estimated actual damages; a 33%

attorney fee award of the estimated actual damages which would be $180,920.00; injunctive relief based on the taxes that Defendant would annually cease over- collecting, which equals a discounted $871,158.16 over the next 10 years and

$1,392,752.72 over the next 20 years, and a “conservative estimation” of punitive damages at a ratio of 7:1 which would be $3,799,320.00 and a 27:1 ratio of $14,654,520.00, respectively. The amount in controversy would range from

$5,394,158.16 to $16,770,952.70, all above the CAFA threshold. Standard of Review CAFA “confers federal jurisdiction over class actions where, among other things, 1) there is minimal diversity; 2) the proposed class contains at least 100

members; and 3) the amount in controversy is at least $5 million in the aggregate.” Plubell v. Merck & Co., 434 F.3d 1070, 1071 (8th Cir. 2006) (citing 28 U.S.C. § 1332(d)); see also Raskas v. Johnson & Johnson, 719 F.3d 884, 886–87 (8th Cir.

2013). Plaintiff does not dispute that this action satisfies the CAFA requirements of minimal diversity and having at least 100 members. He argues, however, that Defendant has not met the burden of establishing the amount in controversy, i.e., $5 million in the aggregate.

Federal courts are courts of limited jurisdiction, and “[i]t is to be presumed that a cause lies outside this limited jurisdiction[.]” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994). “[T]he burden of establishing the contrary

rests upon the party asserting jurisdiction[.]” Id. (citations omitted). The Court may exercise jurisdiction over this removed case only if it would have had original subject-matter jurisdiction had the action initially been filed here. Krispin v. May

Dep’t Stores Co., 218 F.3d 919, 922 (8th Cir. 2000) (citing 28 U.S.C. § 1441(b)). The Court reviews the state-court petition pending at the time of removal to determine the existence of subject-matter jurisdiction. St. Paul Mercury Indem. Co.

v. Red Cab Co., 303 U.S. 283, 291–92 (1938). The notice of removal may also be considered to determine jurisdiction. 28 U.S.C. § 1446(c)(2)(A)(ii). Defendant, as the removing party invoking jurisdiction, bears the burden of proving that all prerequisites to jurisdiction are satisfied. Kokkonen, 511 U.S. at

377; In re Prempro Prods. Liab. Litig., 591 F.3d 613, 620 (8th Cir. 2010). See also Westerfeld v. Independent Processing, LLC, 621 F.3d 819, 822 (8th Cir. 2010) (“Although CAFA expanded federal jurisdiction over class actions, it did not alter

the general rule that the party seeking to remove a case to federal court bears the burden of establishing federal jurisdiction.”). Where, as here, “the class action complaint does not allege that more than $5 million is in controversy, ‘a defendant’s notice of removal need include only a plausible allegation that the

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