Monette v. The Procter & Gamble Manufacturing Company

CourtDistrict Court, M.D. Louisiana
DecidedMarch 10, 2025
Docket3:24-cv-00798
StatusUnknown

This text of Monette v. The Procter & Gamble Manufacturing Company (Monette v. The Procter & Gamble Manufacturing Company) 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
Monette v. The Procter & Gamble Manufacturing Company, (M.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF LOUISIANA

RACHEL MONETTE CIVIL ACTION

VERSUS NO. 24-798-SDD-RLB

THE PROCTOR & GAMBLE MANUFACTURING COMPANY, ET AL.

NOTICE

Please take notice that the attached Magistrate Judge’s Report has been filed with the Clerk of the United States District Court.

In accordance with 28 U.S.C. § 636(b)(1), you have fourteen (14) days after being served with the attached Report to file written objections to the proposed findings of fact, conclusions of law and recommendations therein. Failure to file written objections to the proposed findings, conclusions, and recommendations within 14 days after being served will bar you, except upon grounds of plain error, from attacking on appeal the unobjected-to proposed factual findings and legal conclusions of the Magistrate Judge which have been accepted by the District Court.

ABSOLUTELY NO EXTENSION OF TIME SHALL BE GRANTED TO FILE WRITTEN OBJECTIONS TO THE MAGISTRATE JUDGE’S REPORT.

Signed in Baton Rouge, Louisiana, on March 10, 2025.

S RICHARD L. BOURGEOIS, JR. U NITED STATES MAGISTRATE JUDGE UNITED STATES DISTRICT COURT

MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION

Before the Court is Plaintiff’s Motion to Remand. (R. Doc. 18). The motion is opposed. (R. Docs. 21, 26). I. Background On or about August 21, 2024, Rachel Monette on behalf of her minor son K. H. (“Plaintiff”), initiated this personal injury action against The Procter & Gamble Manufacturing Company and Procter & Gamble Distributing, LLC (collectively, “Defendants”) in the 19th Judicial District Court, Parish of East Baton Rouge, Louisiana. (R. Doc. 1-2, “Petition”). Plaintiff alleges that she washed K.H.’s pajamas using a Tide Pod manufactured by Defendants, dressed him in the pajamas for the night, and then, the following morning, noticed that the shirt stuck to K.H.’s skin when she tried to remove it the following morning. (Petition ¶¶ 3-7). Plaintiff alleges that she took K.H. “to the emergency room where it was discovered that the Tide Pod used to wash his laundry was stuck to the inside of his shirt causing a second-degree chemical burn to his chest.” (Petition ¶ 8). Based on the foregoing, Plaintiff seeks recovery for, among other things, “severe and permanent physical pain and suffering, loss of enjoyment of life, anxiety, embarrassment, humiliation, and medical expenses,” future damages including nerve damage, and punitive damages. (Petition ¶¶ 13-15, 20-22). On September 25, 2024, Defendants removed this action asserting that the Court can properly exercise diversity jurisdiction pursuant to 28 U.S.C. § 1332. (R. Doc. 1). The Court then issued an order requiring Defendants to submit additional information to establish that the diversity requirement is satisfied. (R. Doc. 12). The Amended Notice of Removal states that the amount in controversy is facially apparent given the allegations in the Petition and that the

parties are diverse because Plaintiff is a citizen of Louisiana and Defendants are citizens of Ohio. (R. Doc. 14). On October 25, 2024, Plaintiff filed the instant Motion to Remand, arguing that the Court lacks diversity jurisdiction in this action because Defendants have not established that the jurisdictional minimum is satisfied. (R. Doc. 18). In short, Plaintiff argues that the amount in controversy is not facially apparent and Defendants have not otherwise proven, by a preponderance of the evidence that the amount in controversy exceeds the jurisdictional minimum. (R. Doc. 18-1 at 2-5). In addition to remand, Plaintiff seeks recovery of costs and expenses, including attorney’s fees, pursuant to 28 U.S.C. § 1447(c). (R. Doc. 18-1 at 5-6).

Defendants opposed the Motion to Remand by arguing that the amount in controversy is facially apparent because the Petition involves injuries involving a minor child, Plaintiff alleges severe injuries involving pain and scarring, Plaintiff has sought punitive damages, and Plaintiff is seeking a jury trial. (R. Doc. 21 at 1-3). Defendants argue that juries in certain jurisdictions have awarded significant punitive damages involving burns and wrongful deaths to minor children, further noting that Plaintiff has not stipulated that the damages sought are less than the jurisdictional amount. (R. Doc. 21 at 3, n.4). If the Court concludes that Defendants have not met their burden to establish the jurisdictional amount, then Defendants seek the opportunity to conduct limited jurisdictional discovery. Finally, Defendants argue that the request for costs and attorney’s fees must be denied, even if remand is granted, because the removal was objectively reasonable. (R. Doc. 21 at 3). Defendants have also submitted a Supplemental Response arguing that the jurisdictional amount is further satisfied in light of Plaintiff’s post-removal settlement demand. (R. Doc. 26). In the attached December 23, 2024 settlement demand, which seeks payment of $200,000,

Plaintiff states that K.H. “was diagnosed with having 1st and 2nd degree chemical burns from the toxic effects of corrosive alkali-like substances” and was treated with antibiotics for a total of $596.07 in medical expenses. (R. Doc. 26-1). II. Law and Analysis A. Legal Standards A defendant may remove “any civil action brought in a State court of which the district courts of the United States have original jurisdiction.” 28 U.S.C. § 1441(a). When original jurisdiction is based on diversity of citizenship, the cause of action must be between “citizens of different States” and the amount in controversy must exceed the “sum or value of $75,000,

exclusive of interest and costs.” 28 U.S.C. § 1332(a)-(a)(1). Subject matter jurisdiction must exist at the time of removal to federal court, based on the facts and allegations contained in the complaint. St. Paul Reinsurance Co., Ltd. v. Greenberg, 134 F.3d 1250, 1253 (5th Cir. 1998) (“[J]urisdictional facts must be judged as of the time the complaint is filed”). Remand is proper if at any time the court lacks subject matter jurisdiction. See 28 U.S.C. § 1447(c). The removal statute, 28 U.S.C. § 1441, is strictly construed and any doubt as to the propriety of removal should be resolved in favor of remand. Gasch v. Hartford Acc. & Indem. Co., 491 F.3d 278, 281-82 (5th Cir. 2007); see also Manguno v. Prudential Prop. & Cas. Ins. Co., 276 F.3d 720, 723 (5th Cir. 2002) (“Any ambiguities are construed against removal because the removal statute should be strictly construed in favor of remand.”); Howery v. Allstate Ins. Co., 243 F.3d 912, 916 (5th Cir. 2001) (“We must presume that a suit lies outside this limited jurisdiction, and the burden of establishing federal jurisdiction rests on the party seeking the federal forum.”).

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Monette v. The Procter & Gamble Manufacturing Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/monette-v-the-procter-gamble-manufacturing-company-lamd-2025.