Rufina Vasquez v. The Home Depot USA

CourtDistrict Court, N.D. Texas
DecidedSeptember 23, 2025
Docket7:25-cv-00039
StatusUnknown

This text of Rufina Vasquez v. The Home Depot USA (Rufina Vasquez v. The Home Depot USA) 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
Rufina Vasquez v. The Home Depot USA, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS WICHITA FALLS DIVISION

§ RUFINA VASQUEZ, § § Plaintiff, § § v. § Civil Action No. 7:25-cv-00039-O § THE HOME DEPOT USA, § § Defendant. § §

FINDINGS, CONCLUSIONS, AND RECOMMENDATION OF THE UNITED STATES MAGISTRATE JUDGE

Before the Court is Plaintiff’s Motion to Remand (ECF No. 10), filed July 9, 2025. Chief United States District Judge Reed O’Connor referred the Motion to the undersigned for hearing, if necessary, and determination or recommendation by Order entered on July 10, 2025. ECF No. 11. After considering the pleadings and the applicable legal authorities, the undersigned RECOMMENDS that Chief Judge O’Connor GRANT the Motion. I. BACKGROUND This is a personal injury case. On March 17, 2023, Plaintiff Rufina Vasquez entered the Home Depot store on Kell East Blvd in Wichita Falls, Texas. ECF No. 1-2 at 5. Vasquez asserts that as she made her purchases at the checkout counter, an unrestrained metal cart struck her and rammed her into the counter. ECF No. 1-2 at 5. Vasquez alleges that this incident caused her injuries and pain. ECF No. 1-2 at 5. Vasquez filed her original petition on March 14, 2025, in the 30th Judicial District Court of Wichita County, Texas against Defendant Home Depot U.S.A., Inc. Vasquez sought monetary relief of “$250,000.00 or less.” ECF No. 1-2 at 4. On April 23, 2025, Home Depot timely removed the case to this Court based on diversity jurisdiction. ECF No. 1 at 1. Vasquez moved to remand the case to state court on July 9, 2025, arguing that the amount in controversy was less than $75,000.00 and offering to stipulate that fact. ECF No. 10. For the reasons stated below, the undersigned concludes that Home Depot properly

removed the case to this Court, and Chief Judge O’Connor should deny Vasquez’s Motion to Remand (ECF No. 10). II. LEGAL STANDARDS Title 28 U.S.C. § 1441(a) permits the removal of any civil action brought in state court of which the district courts of the United States have original jurisdiction. The defendant removed this case based on diversity of citizenship under 28 U.S.C. § 1332. ECF No. 1 at 1. A district court can properly exercise jurisdiction on diversity of citizenship only if: (1) the parties are of completely diverse citizenship; and (2) the amount in controversy exceeds $75,000.00. See 28 U.S.C. § 1441(a). After the defendant removes a case to federal court, the case must be remanded to state court “[i]f at any time before final judgment it appears that the district court lacks subject

matter jurisdiction.” Wells Fargo Bank, N.A. v. Adams, No. 3:13-CV-1353-O, 2013 WL 3829494, at *2 (N.D. Tex. July 24, 2013) (citing 28 U.S.C. § 1447(c)). “When a defendant seeks to remove a case, the question of whether jurisdiction exists is resolved by looking at the complaint at the time the petition for removal is filed.” Brown v. Sw. Bell Tel. Co., 901 F.2d 1250, 1254 (5th Cir. 1990)). And “[a]s the party seeking removal, [the removing defendan[t] bear[s] the burden of proving” both complete diversity and that the amount in controversy requirement is met. Hood ex rel. Miss. v. JP Morgan Chase & Co., 737 F.3d 78, 85 (5th Cir. 2013). If the plaintiff's state court petition “demands monetary relief of a stated sum, that sum, if asserted in good faith, is ‘deemed to be the amount in controversy.’” Cherokee Basin

Operating Co., LLC v. Owens, 574 U.S. 81, 84 (2014) (citing § 1446(c)(2)). If the complaint “does not state the amount in controversy, the defendant's notice of removal may do so.” Id. (citing § 1446(c)(2)(A)). The defendant’s notice of removal must only include a short and plain statement plausibly alleging the claim meets the requisite jurisdictional amount and does not “need to prove [the amount] to a legal certainty.” Id. at 88-89 (citing H.R. Rep. No. 112-10, at 16 (2011)).

If the plaintiff does not contest the defendant’s amount-in-controversy allegation, the court should accept the allegation. Id. at 87. If the plaintiff contests it, removal is proper “‘if the district court finds, by the preponderance of the evidence, that the amount in controversy exceeds’ the jurisdictional threshold.” Id. III. ANALYSIS A. The parties are completely diverse. For purposes of diversity jurisdiction, Vasquez is a resident and citizen of Texas. ECF No. 1 at 2. Home Depot is a corporation incorporated in Delaware with its principal place of business in Georgia and thus is a citizen of both Delaware and Georgia. Id. The first requirement of diversity jurisdiction is satisfied because at the time of filing, both parties were completely diverse.

B. The amount in controversy does not supports removal. a. Vasquez’s original petition did not state a sum certain. When pleading in Texas state court, if a plaintiff’s original pleading “specifies a dollar amount, that amount controls if made in good faith.” Guijarro v. Enter. Holdings, Inc., 39 F.4th 309, 314 (5th Cir. 2022). If the plaintiff requests damages of an indeterminate amount, the removing defendant must show “by a preponderance of the evidence that the amount in controversy” has been met. De Aguilar v. Boeing Co., 11 F.3d 55, 58 (5th Cir. 1993). “The defendant can meet that burden in one of two ways: (1) by establishing that it is ‘facially apparent’ that the claims are likely to exceed $75,000, or (2) by setting forth the facts in controversy that support a finding of the requisite amount.” Guijarro 39 F.4th at 314 (citing Luckett v. Delta Airlines, Inc., 171 F.3d 295, 298 (5th Cir. 1999)). Under Texas Rule of Civil Procedure 47, a pleading stating a claim for monetary relief must include “a statement that the party seeks” monetary relief in a range of dollar amounts recover

rather than a specific sum. When a plaintiff seeks monetary relief in the range of $250,000.00- $1,000,000.00 or relief over $1,000,000.00, this pleading is sufficient for removal whether viewed as a sum certain or indeterminate amount. Werder v. Allstate Fire & Cas. Ins. Co., 731 F. Supp. 3d 724, 735 (N.D. Tex. 2024). It makes no difference which view a court takes of such a range because it is “either a request for a specific amount of damages that exceeds $75,000 and which the Court presumes is controlling, or it is an indeterminate amount of damages from which it is facially apparent that [the plaintiff] seeks in excess of $75,000.” Id. (citing Torres v. Guardsmark, LLC, No. 5:15-CV-184 RP, 2016 WL 11602002, at *3 (W.D. Tex. Aug. 3, 2016)). However, a Texas state court pleading that seeks damages of $250,000.00 or less “is, for purposes of 28 U.S.C. § 1446(c)(2), an ‘indeterminate’ or ‘unspecified amount of damages[,]’

[b]ecause ‘an amount less than or equal to $250,000 could be greater than $75,000, or it could be less than $75,000.’” Werder, 731 F. Supp. 3d at 736 (citing Adame v. Bunton, No. EP-22-CV- 00464-DCG, 2022 WL 20158117, at *2 (W.D. Tex. Dec. 28, 2022)).

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Related

De Aguilar v. Boeing Co.
11 F.3d 55 (Fifth Circuit, 1993)
De Aguilar v. Boeing Co.
47 F.3d 1404 (Fifth Circuit, 1995)
Luckett v. Delta Air Lines, Inc
171 F.3d 295 (Fifth Circuit, 1999)
Manguno v. Prudential Property & Casualty Insurance
276 F.3d 720 (Fifth Circuit, 2002)
In the Matter of Shell Oil Company
970 F.2d 355 (Seventh Circuit, 1992)
Jim Hood v. JP Morgan Chase & Company, et a
737 F.3d 78 (Fifth Circuit, 2013)
Guijarro v. Enterprise Holdings
39 F.4th 309 (Fifth Circuit, 2022)

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Bluebook (online)
Rufina Vasquez v. The Home Depot USA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rufina-vasquez-v-the-home-depot-usa-txnd-2025.