Rhonda R. Boyer v. American Furniture Rentals, Inc.

CourtDistrict Court, C.D. California
DecidedOctober 5, 2022
Docket2:22-cv-05740
StatusUnknown

This text of Rhonda R. Boyer v. American Furniture Rentals, Inc. (Rhonda R. Boyer v. American Furniture Rentals, Inc.) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rhonda R. Boyer v. American Furniture Rentals, Inc., (C.D. Cal. 2022).

Opinion

Case 2:22-cv-05740-MCS-GJS Document 26 Filed 10/05/22 Pagelof5 Page ID #:4322

UNITED STATES DISTRICT COURT JS-6 CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES — GENERAL

Case No. 2:22-cv-05740-MCS-GJS Date October 5, 2022 Title Boyer v. Am. Furniture Rentals, Inc.

Present: The Honorable Mark C. Scarsi, United States District Judge

Stephen Montes Kerr Not Reported Deputy Clerk Court Reporter

Attorney(s) Present for Plaintiff(s): Attorney(s) Present for Defendant(s): None Present None Present

Proceedings: (IN CHAMBERS) ORDER RE: MOTION TO REMAND (ECF No. 18) (JS-6)

Plaintiff Rhonda R. Boyer moves to remand this case to the Los Angeles County Superior Court. (Mot., ECF No. 18.) Defendants American Furniture Rentals, Inc., Lauren Goldberg, and Alex Carril filed a brief opposing the motion, (Opp’n, ECF No. 24), and Plaintiff filed a reply, (Reply, ECF No. 25). The Court deems the motion appropriate for decision without oral argument and vacates the hearing set for October 17, 2022. Fed. R. Civ. P. 78(b); C.D. Cal. R. 7-15. I. BACKGROUND This case concerns disability discrimination in employment. Plaintiff worked for American Furniture Rentals and claims that Goldberg, her supervisor, became critical of Plaintiff’s performance and disparaged Plaintiff’s after she became aware of Plaintiff’s breast cancer diagnosis. Plaintiff alleges that Carril, a general manager, also knew of the diagnosis, ratified or approved Goldberg’s conduct, and facilitated Goldberg’s harassing conduct. Ultimately, Plaintiff was furloughed. (See generally Compl., ECF No. 1-4; FAC, ECF No. 1-10.)

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Case 2:22-cv-05740-MCS-GJS Document 26 Filed 10/05/22 Page 2 of 5 Page ID #:4323

After nearly two years of litigation in the state court, Plaintiff maintained one remaining claim against Carril for intentional infliction of emotional distress. (FAC ¶¶ 100–07; see Notice of Removal ¶ 8, ECF No. 1.) Carril filed a motion for summary judgment as to this claim, and Plaintiff filed an opposition brief. (Suppl. to Notice of Removal, vol. 8, at 55–61, ECF No. 22-3;1 Lee Decl. Ex. 14, ECF No. 1-17.) Having reviewed Plaintiff’s brief, Defendants removed the case to this Court six days before the state court hearing on Carril’s motion. Defendants submit that Plaintiff’s opposition made clear that her claim against Carril lacked merit, meaning that Carril was fraudulent joined to the action. (Notice of Removal ¶¶ 23–24; see generally Lee Decl. Ex. 14.)

II. LEGAL STANDARD

“Federal courts are courts of limited jurisdiction” and “possess only that power authorized by Constitution and statute.” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994). A defendant may remove an action to federal court if the federal court could exercise original jurisdiction over the action. 28 U.S.C. § 1441(a). “The removal statute is strictly construed against removal jurisdiction,” and “[t]he defendant bears the burden of establishing that removal is proper.” Provincial Gov’t of Marinduque v. Placer Dome, Inc., 582 F.3d 1083, 1087 (9th Cir. 2009). If a defendant fails to meet its burden of establishing subject-matter jurisdiction, the suit is remanded. 28 U.S.C. § 1447(c).

III. DISCUSSION

Defendants invoke the Court’s diversity jurisdiction, but they concede that Carril and Plaintiff are both California citizens. (Notice of Removal ¶¶ 2, 12, 15, 19, 25.) Defendants claim Carril was fraudulently joined to this action. (Id. ¶¶ 19–24; see generally Opp’n.) In evaluating diversity jurisdiction, the Court “may disregard the citizenship of a non-diverse defendant who has been fraudulently joined.” GranCare, LLC v. Thrower, 889 F.3d 543, 548 (9th Cir. 2018). “There are two ways to establish fraudulent joinder: ‘(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.’” Id. (quoting Hunter v. Philip Morris USA, 582 F.3d 1039, 1044 (9th Cir. 2009)). In evaluating a claim of fraudulent joinder, a court must remand “if there is a possibility that a state court would find that the complaint states

1 The Court’s pinpoint citations of the supplement to the notice of removal refer to the page numbers assigned by CM/ECF.

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a cause of action against any of the [non-diverse] defendants.” Id. (quoting Hunter, 582 F.3d at 1046). In this inquiry, “the district court must consider . . . whether a deficiency in the complaint can possibly be cured by granting the plaintiff leave to amend.” Id. at 550. There is a presumption against fraudulent joinder, and “defendants who assert fraudulent joinder carry a heavy burden of persuasion.” Tanner v. Ford Motor Co., 424 F. Supp. 3d 666, 670 (N.D. Cal. 2019).

Defendants contend the claim against Carril is inadequately pleaded. (Opp’n 5–6.) The state court rejected Defendants’ argument over a year ago in an order overruling Defendants’ demurrer. (Suppl. to Notice of Removal, vol. 10, at 446–49, ECF No. 23-1.) Here there is a certainty, not merely “a possibility[,] that a state court would find that the complaint states a cause of action.” GranCare, 889 F.3d at 548 (internal quotation marks omitted). In any event, the Court cannot conclude that any perceived defect in the pleading of the claim could not be cured upon an amendment adding facts about Carril’s “extreme and outrageous conduct.” Hughes v. Pair, 46 Cal. 4th 1035, 1050 (2009) (internal quotation marks omitted) (discussing elements of intentional infliction of emotional distress); see GranCare, 889 F.3d at 550 (requiring courts to consider whether amendment could cure pleading defects).

Defendants also reiterate arguments Carril made in his motion for summary judgment that was pending in state court when Defendants removed the case. They contend that, after failing to seek evidence against Carril in the discovery period in state court, Plaintiff lacks evidence to support her claim, and her deposition testimony forecloses a judgment in her favor. (See Opp’n 6–11.) Essentially, Defendants ask the Court to adjudicate the merits of the claim against Carril. The Court cannot do so in a fraudulent joinder inquiry. The Ninth Circuit has instructed district courts to conduct only a “summary inquiry” into fraudulent joinder. Hunter v. Philip Morris USA, 582 F.3d 1039, 1044 (9th Cir. 2009) (quoting Smallwood v. Ill. Cent. R.R. Co., 385 F.3d 568, 573 (5th Cir. 2004)); see also GranCare, 889 F.3d at 548–49 (“We have declined to uphold fraudulent joinder rulings where a defendant raises a defense that requires a searching inquiry into the merits of the plaintiff’s case, even if that defense, if successful, would prove fatal.”).

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Related

Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Hunter v. Philip Morris USA
582 F.3d 1039 (Ninth Circuit, 2009)
Provincial Gov't of Marinduque v. Placer Dome, Inc.
582 F.3d 1083 (Ninth Circuit, 2009)
Hughes v. Pair
209 P.3d 963 (California Supreme Court, 2009)
Grancare v. Ruth Thrower
889 F.3d 543 (Ninth Circuit, 2018)
Morris v. Princess Cruises, Inc.
236 F.3d 1061 (Ninth Circuit, 2001)

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Bluebook (online)
Rhonda R. Boyer v. American Furniture Rentals, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/rhonda-r-boyer-v-american-furniture-rentals-inc-cacd-2022.