Moody v. Coca-Cola Bottling Company United, Inc.

CourtDistrict Court, E.D. Louisiana
DecidedJanuary 22, 2025
Docket2:24-cv-02579
StatusUnknown

This text of Moody v. Coca-Cola Bottling Company United, Inc. (Moody v. Coca-Cola Bottling Company United, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Moody v. Coca-Cola Bottling Company United, Inc., (E.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

DENISE MOODY, CIVIL ACTION Plaintiff

VERSUS NO. 24-2579

COCA-COLA BOTTLING COMPANY SECTION: “E” (1) UNITED, INC., ET AL., Defendants

ORDER AND REASONS

Before the Court is a motion to remand filed by Plaintiff Denise Moody (“Plaintiff”).1 Defendants Walmart Inc., Wal-Mart Louisiana, LLC, and Brandon Sylve (“Sylve”) (collectively, “Walmart Defendants”) filed an opposition.2 Defendant Coca-Cola Bottling Company United, Inc. (“Coca-Cola”) filed a separate opposition.3 BACKGROUND On July 11, 2024, Plaintiff filed a petition for damages in the 17th Judicial District Court for the Parish of Lafourche.4 Plaintiff alleges that on July 11, 2023, she entered a Walmart store in Thibodaux, Louisiana and while there slipped in a pool of water as she was making her way to the checkout area.5 Plaintiff alleges the water came “from under a beverage cooler,” which she “believed to be owned by Coca-Cola.”6 Plaintiff brings negligence claims against the Walmart Defendants and Coca-Cola (collectively, “Defendants”).7 Plaintiff alleges her accident and injuries “were caused by the individual

1 R. Doc. 17. 2 R. Doc. 18. 3 R. Doc. 19. 4 R. Doc. 1-1. 5 Id. at p. 2. 6 Id. 7 Id. at pp. 2-4. negligence or fault of defendant, Walmart, and its management, specifically including but not limited to Manager Brandon Sylve, and employees, and/or Coca-Cola, and its management and employees.”8 Plaintiff then lists the particular ways in which she alleges the defendants were negligent: A. Creating and/or permitting the unreasonably hazardous condition to remain on the store’s floor;

B. Failure to maintain or construct the premises in a safe condition for the circumstances presented;

C. Failing to implement proper safety, maintenance, or clean up procedures, to address the puddle of liquid on the store’s floor and/or for other reasons within the Defendant’s control;

D. Failure to warn the Plaintiff of a known dangerous condition;

E. Failure to station an employee in the area of the leak to warn customers of the liquid;

F. Failure to place hazard signs in a proper location that would have provided the Plaintiff with prior notice of the liquid;

G. Failure to warn Plaintiff by way of signs, barricades or by any means, of the hazard or danger;

H. Failure to timely remedy or clean up a known dangerous condition in the walkway;

I. Failure to maintain beverage coolers to prevent leaking;

J. Failure to properly service beverage coolers or merchandisers;
K. Failure to exercise due care and caution under all of the circumstances;

L. Failure to meet generally the standard of care required under the circumstances;

M. Any and all other acts of negligence, fault or imprudence which may be proven during the investigation and/or trial of the merits of this matter, all of which are in violation of the laws of the State of Louisiana and applicable

8 Id. at p. 3. Parish ordinances, which are hereby pleaded and adopted by this reference as though set forth in extenso.9

On August 13, 2024, the Walmart Defendants filed an answer.10 On August 16, 2024, Coca-Cola filed a dilatory exception of vagueness because Plaintiff’s allegations “concerning the amount in controversy fail[ed] to indicate whether it is such that there is a lack of jurisdiction of federal courts.”11 In response to Coca-Cola’s dilatory exception, Plaintiff, with leave of the state court, filed a first amended petition for damages on October 1, 2024.12 In the first amended petition, Plaintiff added an allegation that “the monetary amount of Plaintiff’s cause of action herein, exceeds the requisite amount to establish the jurisdiction of the federal courts.”13 In the motion to remand, Plaintiff states that, “There were no substantive or factual amendments and no changes to the specification of damages sustained.”14 Coca-Cola then withdrew its dilatory exception as moot.15 On October 30, 2024, this case was removed to federal court on the basis of the Court’s diversity-of-citizenship jurisdiction.16 The parties do not contest the amount in controversy or whether it exceeds the jurisdictional threshold of $75,000, exclusive of interest and costs.17 The parties disagree, however, on whether the complete diversity-of- citizenship requirement is satisfied. It is undisputed that Plaintiff is a citizen of Louisiana for purposes of diversity jurisdiction and that Sylve also is a Louisiana citizen. Thus, complete diversity is, on its face, not present between Plaintiff and Sylve. According to the

9 Id. at pp. 3-4. 10 R. Doc. 1-7 at pp. 20-26. 11 Id. at pp. 31-36. 12 Id. at pp. 55-57. 13 Id.; R. Doc. 17-1 at pp. 2-3. 14 R. Doc. 17-1 at p. 3. 15 R. Doc. 1-7 at pp. 59-60. 16 R. Doc. 1. 17 Id.; R. Doc. 12; R. Doc. 17-1. Walmart Defendants, however, federal diversity jurisdiction is proper, despite the fact that Plaintiff and Sylve share Louisiana citizenship, because Plaintiff improperly joined Sylve as a defendant.18 Walmart Defendants argue Plaintiff improperly joined Sylve because Plaintiff only raised “general administrative” responsibility allegations against Sylve.19 Further, Walmart Defendants represented that Sylve did not work on the day of

Plaintiff’s slip-and-fall.20 On November 4, 2024, the Court ordered Walmart Defendants to amend their notice of removal because of deficiencies in Walmart Defendants’ jurisdictional allegations related to the amount in controversy and the domicile of Defendant Wal-Mart Louisiana, LLC.21 Walmart Defendants timely filed an amended notice of removal on November 14, 2024.22 Following review of the amended notice of removal, the Court, on November 25, 2024, held a telephone status conference to discuss Walmart Defendants’ improper joinder argument. The Court permitted Plaintiff to file a motion to remand on or before December 27, 2024.23 Plaintiff timely filed a motion to remand arguing that (1) Defendants waived the defense of improper joinder; (2) Walmart Defendants’ removal

was untimely; (3) the parties are not completely diverse; and (4) the Defendants have not proven that there is no possibility of recovery against Sylve.24 Walmart Defendants and Coca-Cola each filed an opposition.25

18 R. Doc. 1 at pp. 3-5. 19 Id. at p. 4. 20 Id. 21 R. Doc. 9. 22 R. Doc. 12. 23 R. Doc. 15. 24 R. Doc. 17-1. 25 R. Doc. 18; R. Doc. 19. LEGAL STANDARD It is the removing party’s burden to establish improper joinder, and the burden is a “heavy” one.26 The Fifth Circuit has recognized two ways for the removing party to establish improper joinder: (1) “actual fraud in the pleading of jurisdictional facts;” or (2) an “inability of the plaintiff to establish a cause of action against the non-diverse party in

state court.”27 There is no allegation of actual fraud in this case. “The test for improper joinder where there is no allegation of actual fraud is whether the defendant has demonstrated that there is no possibility of recovery by the plaintiff against an in-state defendant.”28 “In determining the validity of an allegation of improper joinder, the district court must construe factual allegations, resolve contested factual issues, and resolve ambiguities in the controlling state law in the plaintiff’s favor.”29 In Smallwood v. Illinois Central Railroad Co., the Fifth Circuit articulated two avenues for determining whether a plaintiff has a reasonable basis for recovery under state law.30 First, “[t]he court may conduct a Rule 12(b)(6)-type analysis, looking initially at the allegations of the complaint to determine whether the complaint states a claim under state law against the in-state

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Bluebook (online)
Moody v. Coca-Cola Bottling Company United, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/moody-v-coca-cola-bottling-company-united-inc-laed-2025.