Rodriguez v. Costco Wholesale Corporation

CourtDistrict Court, N.D. California
DecidedOctober 24, 2024
Docket4:24-cv-01413
StatusUnknown

This text of Rodriguez v. Costco Wholesale Corporation (Rodriguez v. Costco Wholesale Corporation) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rodriguez v. Costco Wholesale Corporation, (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 MAYTE RODRIGUEZ, Case No. 24-cv-01413-JSW 8 Plaintiff, ORDER DENYING PLAINTIFF’S MOTION TO REMAND AND SETTING 9 v. INITIAL CASE MANAGEMENT CONFERENCE 10 COSTCO WHOLESALE CORPORATION, Re: Dkt. No. 7 Defendant. 11 12 13 Now before the court is Plaintiff Mayte Rodriguez’s (“Plaintiff”) motion to remand. The 14 Court has considered the parties’ papers, relevant legal authority, and the record in this case. For 15 the reasons stated below, the Court DENIES Plaintiff’s motion to remand. 16 BACKGROUND 17 On September 24, 2021, Plaintiff alleges she slipped and fell on smashed produce at 18 Defendant Costco Corporation’s (“Defendant”) location at 4801 Central Avenue in Richmond, 19 California. Plaintiff alleges that the spilled produce was not timely cleaned up and caused her to 20 suffer significant injuries to her hip and knee. According to a pre-suit settlement demand letter, to 21 treat those injuries, Plaintiff underwent physical therapy, right knee arthroscopy, and medial plica 22 removal. (Declaration of Nathaniel L. Dunn (“Dunn Decl.”), ¶ 6, Ex. B.) 23 Plaintiff’s pre-suit settlement demand listed the cost of her medical bills as $62,725.77. 24 Her demand for damages included past pain and suffering, future medical expenses, and future 25 pain and suffering. (Id., ¶ 7, Ex. B.) On August 17, 2023, Plaintiff filed a Complaint in Contra 26 Costa Superior Court (“Superior Court”), in which she did not allege a total amount of damages 27 but checked off the categories of wage loss, hospital and medical expenses, general damages, loss 1 no specific amount provided within any of those categories of damages. (Id., ¶ 7, Ex. A.) On 2 January 31, 2024, Plaintiff filed a case management statement, in which she alleged that her 3 medical expenses were approximately $70,000.00. (Id., ¶ 11, Ex. C.) 4 On February 15, 2024, Defendant timely filed an Answer to Plaintiff’s Complaint. On 5 March 8, 2024, Defendant filed a Notice of Removal to federal court and asserted the Court had 6 diversity jurisdiction under 28 U.S.C. Section 1332. On April 5, 2024, Plaintiff timely filed a 7 Motion to Remand to Superior Court arguing that this Court does not have subject matter 8 jurisdiction because Defendant had failed to establish that the amount-in-controversy is greater 9 than $75,000. 10 ANALYSIS 11 A. Applicable Legal Standards. 12 Pursuant to 28 U.S.C. section 1441(a), a defendant may remove any civil action brought in 13 a state court to the district court where such action is pending so long as the court to which the 14 case is removed has “original jurisdiction” over the case. Matheson v. Progressive Specialty Ins. 15 Co., 319 F.3d 1089, 1090 (9th Cir. 2003). However, federal courts are courts of limited 16 jurisdiction. See, e.g., Kokkonen v. Guardian Life Ins. Co. Am., 511 U.S. 375, 377 (1994). The 17 party seeking removal has the burden of establishing federal jurisdiction, and the removal statute 18 is strictly construed against removal jurisdiction. Valdez v. Allstate Ins. Co., 372 F.3d 1115, 1116- 19 17 (9th Cir. 2004). 20 A federal court has original jurisdiction where the case concerns an issue of federal law or 21 there is complete diversity between the parties and the amount in controversy exceeds $75,000. 22 28 U.S.C. §1441(a). Here, there are no federal claims and the parties do not dispute that there is 23 complete diversity. The jurisdictional issue thus solely concerns whether the $75,000 amount in 24 controversy requirement has been satisfied. 25 Plaintiff does not allege an amount in controversy in her Complaint. In the Ninth Circuit, 26 if it is “unclear or ambiguous from the face of a state-court complaint whether the requisite 27 amount in controversy is pled[,] ... a preponderance of the evidence standard” applies. 1 Monumental Life Ins. Co., 102 F.3d 398, 402 (9th Cir. 1996)). In determining the amount in 2 controversy under that standard, courts “consider the allegations in the complaint and in the notice 3 of removal, as well as summary judgment-type evidence.” Chavez v. JPMorgan Chase & Co., 4 888 F.3d 413, 416 (9th Cir. 2018). 5 The amount in controversy may include, for example, “damages (compensatory, punitive, 6 or otherwise) and ... attorneys’ fees awarded under fee shifting statutes.” Gonzales v. CarMax 7 Auto Superstores, LLC, 840 F.3d 644, 648-49 (9th Cir. 2016); see also Tanious v. Gattoni, 533 F. 8 Supp. 3d 770, 777 (N.D. Cal. 2021). “[T]he amount in controversy ... is determined by the 9 complaint operative at the time of removal and encompasses all relief a court may grant on that 10 complaint if the plaintiff is victorious.” Chavez, 888 F.3d at 414-15. Courts consider only the 11 “amount at stake in the underlying litigation, not the likely liability.” Gonzales, 840 F.3d at 648. 12 The amount at stake in the underlying litigation can include estimates of future damages. Chavez 13 888 F.3d at 417 (“the mere futurity of certain classes of damages” does not preclude them from 14 being included in the present amount in controversy). 15 B. Defendant Has Met Its Burden to Show the Amount in Controversy Requirement. 16 Defendant argues that, cumulatively, Plaintiff’s demands for medical costs and for multiple 17 categories of damages alleged in her settlement documents and in her Complaint satisfy the 18 amount in controversy requirement. Plaintiff counters that Defendant’s calculations are 19 “speculative” and argues that if the Court has “any doubt” about removal, then the case must be 20 remanded. (Motion at 4:18.) Plaintiff also argues that her initial position on medical damages 21 was merely an “optimistic prediction,” and the Court should not use those figures in assessing the 22 jurisdictional requirements. (Id. at 5:10.) 23 In the Ninth Circuit, a “settlement letter is relevant evidence of the amount in controversy 24 if it appears to reflect a reasonable estimate of the plaintiff’s claim.” Cohn v. Petsmart, Inc., 281 25 F.3d 837, 840 (9th Cir. 2002). The Cohn court also found it significant that the plaintiff made no 26 attempt to disavow the settlement demand or to offer contrary evidence despite opportunities to do 27 so, the settlement demand is entitled to greater weight. Id. 1 conference paperwork—$62,725.77 and $70,000 respectively—“appear to reflect a reasonable 2 estimate of [her] claim” given the nontrivial injury she alleges. Id. Plaintiff stated that she 3 underwent right knee arthroscopy and medial plica removal as well as physical therapy. Plaintiff’s 4 counsel also later confirmed via email that Plaintiff had undergone arthroscopic knee surgery. 5 (Dunn Decl., ¶¶ 5,14.) Plaintiff has discussed specific medical procedures on her knee and that 6 she has had physical therapy because of the injury. (Id., ¶ 5.) Moreover, Plaintiff had ample 7 opportunity “to disavow the settlement demand or offer contrary evidence” before moving to 8 remand but did not do so. Cohn, 281 F.3d at 840.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Lillian Corder Roberta Lombardo v. Roy Brown
25 F.3d 833 (Ninth Circuit, 1994)
Matheson v. Progressive Specialty Insurance Company
319 F.3d 1089 (Ninth Circuit, 2003)
Simmons v. PCR TECHNOLOGY
209 F. Supp. 2d 1029 (N.D. California, 2002)
Travis Gonzales v. Carmax Auto Superstores, LLC
840 F.3d 644 (Ninth Circuit, 2016)
Elsa Chavez v. Jpmorgan Chase Bank
888 F.3d 413 (Ninth Circuit, 2018)
Mireles v. Wells Fargo Bank, N.A.
845 F. Supp. 2d 1034 (C.D. California, 2012)
Olsen v. Isbrandtsen Co.
209 F. Supp. 6 (S.D. New York, 1962)

Cite This Page — Counsel Stack

Bluebook (online)
Rodriguez v. Costco Wholesale Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rodriguez-v-costco-wholesale-corporation-cand-2024.