Lorenda Jo Stevenson v. Walmart, Inc. and Monique Waite

CourtDistrict Court, N.D. Texas
DecidedMarch 26, 2026
Docket3:25-cv-01498
StatusUnknown

This text of Lorenda Jo Stevenson v. Walmart, Inc. and Monique Waite (Lorenda Jo Stevenson v. Walmart, Inc. and Monique Waite) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lorenda Jo Stevenson v. Walmart, Inc. and Monique Waite, (N.D. Tex. 2026).

Opinion

NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

LORENDA JO STEVENSON, ) ) Plaintiff, ) ) VS. ) CIVIL ACTION NO. ) WALMART, INC. and ) 3:25-CV-1498-G MONIQUE WAITE, ) ) Defendants. ) MEMORANDUM OPINION AND ORDER Before the court are two motions: (1) the motion of the plaintiff Lorenda Jo Stevenson (“Stevenson”) to remand this case to the state court from which it was previously removed (docket entry 30) and (2) the motion of the defendants Walmart, Inc. (“Walmart”) and Monique Waite (“Waite”) to dismiss Stevenson’s claims under Federal Rule of Civil Procedure 12(b)(6) (docket entry 32). For the reasons stated below, the motion to remand is granted. I. BACKGROUND This case concerns an incident that occurred at Walmart’s store located at 782

East Interstate 30 in Rockwall, Texas. See generally Plaintiff’s First Amended Complaint of August 11, 2025 (“Complaint”) (docket entry 27). Stevenson asserts that on October 6, 2023, Waite, a Walmart employee, “collided with Plaintiff’s damages. Id. On March 19, 2025, Stevenson, a citizen of Texas, filed suit against Walmart, a citizen of Delaware and Arkansas, and the defendant “Jane Doe” in the 382nd District Court of Rockwall County, Texas. See generally Plaintiff’s Original Petition,

Jury Demand, and Request for Mandatory Disclosures Pursuant to TRCP 94, attached to Notice of Removal (“Notice”) (docket entry 1); see also Notice at 2. On June 12, 2025, Walmart removed the case to this court on the basis of diversity of citizenship jurisdiction.1 See Notice ¶ 5. After a period of limited discovery to identify Jane Doe, on August 11, 2025,

Stevenson identified Waite, a Texas citizen, by name in a first amended complaint. See Complaint; see also Brief in Support of Plaintiff’s Response in Opposition to Defendants’ Rule 12(b)(6) Motion to Dismiss (docket entry 36) at 10. Stevenson alleges alternative theories of negligence against both defendants, as well as premises

1 Wal-Mart was entitled to remove the case before inquiring into John Doe’s identity and citizenship in order to do so timely. 28 U.S.C. § 1446(b)(1). However, once the employee’s identity has been revealed and he is substituted for the John Doe Defendant, the employee’s citizenship can destroy diversity and require remand. Id.; 28 U.S.C. § 1447 (“If at any time before final judgment it appears that the district court lacks subject matter jurisdiction, the case shall be remanded.”). Garcia v. Walmart, Inc., No. 2:20-CV-0075, 2020 WL 2576239, at *2 (S.D. Tex. May 21, 2020). Walmart. See Complaint ¶¶ IV-VI. The defendants argue that Stevenson’s vague and unclear assertions are insufficient to state a claim. Defendants’ Brief in Support of 12(b)(6) Motion (“Motion to Dismiss”) (docket entry 33) at 2; see also Defendants’ Response to Plaintiff’s Motion for Remand and Brief in Support (“Response to

Motion to Remand”) (docket entry 34) at 3 n.1. Stevenson moves to remand this case to the state court, arguing that removal was improper because the parties lack complete diversity of citizenship. See generally Brief in Support of Plaintiff’s Opposed Motion to Remand to State Court (“Motion to Remand”) (docket entry 31). The defendants assert that Stevenson improperly

joined Waite, a Texas citizen, to defeat diversity jurisdiction and urges the court to dismiss Waite as a party to this lawsuit. Response to Motion to Remand at 7. The parties do not dispute that the amount in controversy exceeds $75,000, and the parties’ citizenship is undisputed. Therefore, the only issue before the court is

whether Waite was properly joined as a defendant. II. ANALYSIS A. Legal Standard 1. Removal Jurisdiction 28 U.S.C. § 1441(a) permits the removal of “any civil action brought in a

[s]tate court of which the district courts of the United States have original jurisdiction.” 28 U.S.C. § 1441(a). The statute allows a defendant to “remove a state court action to federal court only if the action could have originally been filed in However, the removal statute must be strictly construed because “removal jurisdiction raises significant federalism concerns.” Willy v. Coastal Corporation, 855 F.2d 1160, 1164 (5th Cir. 1988); see also Gutierrez v. Flores, 543 F.3d 248, 251 (5th Cir. 2008). Therefore, “any doubts concerning removal must be resolved against

removal and in favor of remanding the case back to state court.” Cross v. Bankers Multiple Line Insurance Company, 810 F. Supp. 748, 750 (N.D. Tex. 1992) (Means, J.); see also Shamrock Oil & Gas Corporation v. Sheets, 313 U.S. 100, 108-09 (1941). The party seeking removal bears the burden of establishing federal jurisdiction. Willy, 855 F.2d at 1164.

There are two principal bases upon which a district court may exercise removal jurisdiction: the existence of a federal question, see 28 U.S.C. § 1331, and complete diversity of citizenship among the parties. See 28 U.S.C. § 1332. Here, the removing defendant has alleged only diversity of citizenship as a basis for this court’s

jurisdiction. See Notice ¶ 5. The court can properly exercise jurisdiction on the basis of diversity of citizenship after removal only if three requirements are met: (1) the parties are of completely diverse citizenship, see 28 U.S.C. § 1332(a); (2) none of the properly joined defendants is a citizen of the state in which the case is brought, see 28 U.S.C. § 1441(b); and (3) the case involves an amount in controversy of more than

$75,000, see 28 U.S.C. § 1332(a). Diversity of citizenship exists only when none of the defendants is a citizen of the same state as the plaintiff. See 28 U.S.C. § 1332(a). Here, Stevenson and Waite because Waite was improperly joined in this suit. See Response to Motion for Remand. 2. Improper Joinder Even if a defendant has the same citizenship as the plaintiff, a federal court

can still exercise removal jurisdiction over an action if the court finds that the plaintiff improperly joined the non-diverse defendant. The Fifth Circuit has recognized two grounds on which a court can find that a defendant was improperly joined: “‘(1) actual fraud in the pleading of jurisdictional facts, or (2) inability of the plaintiff to establish a cause of action against the non-diverse party in state court.’”

Smallwood v. Illinois Central Railroad Company, 385 F.3d 568, 573 (5th Cir. 2004) (en banc) (quoting Travis v. Irby,

Related

Travis v. Irby
326 F.3d 644 (Fifth Circuit, 2003)
Gutierrez v. Flores
543 F.3d 248 (Fifth Circuit, 2008)
Shamrock Oil & Gas Corp. v. Sheets
313 U.S. 100 (Supreme Court, 1941)
B., Inc. v. Miller Brewing Company
663 F.2d 545 (Fifth Circuit, 1981)
Richard J. Dodson v. Spiliada Maritime Corp.
951 F.2d 40 (Fifth Circuit, 1992)
Gerry M. Griggs v. State Farm Lloyds Lark P. Blum
181 F.3d 694 (Fifth Circuit, 1999)
Cross v. Bankers Multiple Line Insurance
810 F. Supp. 748 (N.D. Texas, 1992)
Leitch v. Hornsby
935 S.W.2d 114 (Texas Supreme Court, 1996)

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