SBI Builders, Inc. v. Liberty Mutual Insurance Company

CourtDistrict Court, N.D. California
DecidedOctober 11, 2024
Docket3:24-cv-04216
StatusUnknown

This text of SBI Builders, Inc. v. Liberty Mutual Insurance Company (SBI Builders, Inc. v. Liberty Mutual Insurance Company) 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
SBI Builders, Inc. v. Liberty Mutual Insurance Company, (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 SBI BUILDERS, INC., Case No. 24-cv-04216-WHO

8 Plaintiff, ORDER GRANTING PLAINTIFF'S 9 v. MOTION TO REMAND AND DENYING AS MOOT DEFENDANTS' MOTION TO 10 LIBERTY MUTUAL INSURANCE DISMISS COMPANY, et al., 11 Re: Dkt. Nos. 8, 16 Defendants.

12 13 Two motions are pending: (1) Plaintiff SBI Builder’s (“SBI”) Motion to Remand 14 (“Remand Motion” or “Remand Mot.”) [Dkt. No. 16], and (2) Defendant Livermore Multifamily 15 Owner, LLC’s (“Livermore”) Motion to Dismiss (“MTD”) [Dkt. No. 8]. Because Livermore was 16 not fraudulently joined, there is no diversity between the parties and no federal jurisdiction. For 17 the following reasons, SBI’s Remand Motion is GRANTED and Livermore’s Motion to Dismiss 18 is DENIED as moot. 19 BACKGROUND 20 In October 2019, Livermore, a property owner and development company, entered into 21 business with a contracting company to construct a multi-residential building in Livermore, 22 California. Complaint (“Compl.”) [Dkt. No. 1] 10, ¶ 8. The original contractor failed to complete 23 the project. Notice of Removal (“Removal Not.”) [Dkt. No. 1] 3:12-15. Liberty Mutual Insurance 24 Company (“Liberty Mutual”), as a surety to the first contractor and pursuant to a “Takeover 25 Agreement” between Liberty Mutual and Livermore, sought a new contractor to finish the project. 26 See Dkt. No. 1 at 58–75. In February 2022, Liberty and SBI entered into a Completion Agreement 27 (“Completion Agreement” or “the Agreement”) in which SBI agreed to act as a general contractor 1 addition to completing the project, the Agreement provided that SBI would repair any defective 2 work resulting from the first contractor. See Completion Agreement at 22–25. SBI alleges that 3 despite its timely and consistent submission of change orders for repairing defective work and 4 completing additional requests at Liberty’s direction that resulted in unanticipated costs, Liberty 5 ultimately refused to approve any change orders or pay SBI in full. Compl. At ¶¶ 10–13. 6 As a result, in December 2023, SBI recorded a mechanics lien against Liberty and 7 Livermore for $9,016,225.33. Dkt. No. 1 at 46 (Mechanic’s Lien). The lien lists Livermore as the 8 owner of the premises where the “labor, service, equipment or materials[] were furnished” and as 9 a beneficiary of SBI’s work. Id. Within two weeks of the lien’s recorded date, Livermore, as 10 Principal, and the Ohio Casualty Insurance Company (“OCIC”), as surety, posted a bond for the 11 release of the lien. Dkt. No. 1 at 53 (Bond). 12 SBI filed a complaint in California Superior Court for the County of Alameda against 13 Liberty Mutual, Livermore, and OCIC. See generally Compl. SBI alleged four causes of action: 14 (1) breach of contract and (2) common counts against Liberty Mutual, (3) quantum meruit against 15 Liberty Mutual and Livermore, and (4) foreclosure of the mechanic’s lien release bond against 16 OCIC.1 Id. at 12–16, ¶¶ 17–36. 17 Liberty Mutual, joined by OCIC and Livermore, then removed the action to this court 18 asserting diversity jurisdiction. Removal Not. 6:8. Liberty Mutual alleged its own diverse 19 citizenship from SBI as well as OCIC’s, and conceded that Livermore, as a limited liability 20 company with members domiciled in California, shares citizenship with SBI. Id. 2:19-28, citing 21 Johnson v. Columbia Props. Anchorage, LP, 437 F.3d 894, 899 (9th Cir. 2006). Liberty Mutual 22 went on to allege that Livermore’s citizenship should not be considered for jurisdictional purposes 23 because SBI erroneously filed a claim against Livermore. Removal Not. 5:16-19. It argued that 24 Livermore was a fraudulently joined party to this action and its citizenship could be disregarded. 25 Id. Livermore also moved to dismiss SBI’s second cause of action against it. See generally Dkt. 26 1 SBI asserts that Liberty paid several subcontractors, but that it is unaware of whether those 27 subcontractors were properly paid. Compl. at 12, ¶ 16. If those sums have been properly paid and 1 No. 8 (MTD). 2 SBI moved to remand on August 9, 2024. See generally Remand Mot. 3 LEGAL STANDARD 4 A defendant sued in state court may remove the action to federal court if the action could 5 have been brought in federal court in the first instance. 28 U.S.C. § 1441(a). A defendant may 6 remove “any civil action brought in a State court of which the district courts . . . have original 7 jurisdiction.” Id. When a civil action is removed solely under § 1441(a), all defendants who have 8 been properly joined and served must join in or consent to the removal of the action. 28 U.S.C. § 9 1446(b)(2)(A). 10 Diversity removal requires complete diversity, meaning that each plaintiff must be of a 11 different citizenship from each defendant. Caterpillar Inc. v. Lewis, 519 U.S. 61, 68 (1996). 12 “Absent unusual circumstances, a party seeking to invoke diversity jurisdiction should be able to 13 allege affirmatively the actual citizenship of the relevant parties.” Kanter v. Warner-Lambert Co., 14 265 F.3d 853, 857 (9th Cir. 2001) (citing Whitmire v. Victus Ltd. t/a Master Design Furniture, 212 15 F.3d 885, 887 (5th Cir.2000)). In determining whether there is complete diversity, district courts 16 may disregard the citizenship of a non-diverse defendant who has been fraudulently joined. 17 Grancare, LLC v. Thrower by & through Mills, 889 F.3d 543, 548 (9th Cir. 2018) (citing 18 Chesapeake & Ohio Ry. Co. v. Cockrell, 232 U.S. 146, 152 (1914)). 19 Under the doctrine of fraudulent joinder, “[j]oinder of a non-diverse defendant is deemed 20 fraudulent, and the defendant’s presence in the lawsuit is ignored for purposes of determining 21 diversity, if the plaintiff fails to state a cause of action against a resident defendant, and the failure 22 is obvious according to the settled rules of the state.” Morris v. Princess Cruises, Inc., 236 F.3d 23 1061, 1067 (9th Cir. 2001) (internal quotations and alteration omitted). There are two ways to 24 establish fraudulent joinder: “(1) actual fraud in the pleading of jurisdictional facts, or (2) inability 25 of the plaintiff to establish a cause of action against the non-diverse party in state court.” Hunter 26 v. Philip Morris USA, 582 F.3d 1039, 1044 (9th Cir. 2009) (quoting Smallwood v. Illinois Cent. 27 R.R. Co., 385 F.3d 568, 573 (5th Cir. 2004)). Fraudulent joinder is established the second way if a 1 Ritchey v. Upjohn Drug Co., 139 F.3d 1313, 1318 (9th Cir. 1998). A defendant invoking federal 2 court diversity jurisdiction on the basis of fraudulent joinder bears a “heavy burden” since there is 3 a “general presumption against [finding] fraudulent joinder.” Hunter, 582 F.3d at 1046 (citations 4 omitted). 5 DISCUSSION 6 I. REMOVAL WAS IMPROPER 7 SBI challenges removal on the ground that defendants have failed to establish that 8 complete diversity exists under 28 U.S.C.

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SBI Builders, Inc. v. Liberty Mutual Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sbi-builders-inc-v-liberty-mutual-insurance-company-cand-2024.