Tillman v. Richman Property Services, Inc.

CourtDistrict Court, S.D. California
DecidedApril 10, 2025
Docket3:24-cv-01598
StatusUnknown

This text of Tillman v. Richman Property Services, Inc. (Tillman v. Richman Property Services, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tillman v. Richman Property Services, Inc., (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 NATALIE TILLMAN, et al., Case No.: 3:24-cv-01598-JES-BLM

12 Plaintiffs, ORDER: 13 v. (1) GRANTING MOTION TO 14 RICHMAN PROPERTY SERVICES, REMAND; INC. et al., 15 Defendants. (2) DENYING MOTION TO 16 TRANSFER OR IN THE 17 ALTERNATIVE, MOTION TO DISMISS AS MOOT 18

19 [ECF Nos. 7, 16]

20 On August 5, 2024, Plaintiffs Natalie Tillman and David Tillman (“Plaintiffs”) 21 initiated this action against Defendant Richman Property Services, Inc. (“Richman”) for 22 violation of California’s Investigative Consumer Reporting Agencies Act (“ICRAA”) in 23 the Superior Court of San Diego, California. ECF No. 1 ¶ 1, Notice of Removal (“NOR”). 24 On September 9, 2024, Richman removed this action to federal court, asserting diversity 25 jurisdiction pursuant to 28 U.S.C. § 1332(a). See generally NOR. On September 30, 2024, 26 Plaintiffs filed a motion to remand. ECF No. 16 (“Motion”). Richman filed an opposition. 27 ECF No. 24 (“Opp’n”). Richman also filed a motion to transfer or in the alternative, motion 28 1 to dismiss. ECF No. 7. Plaintiffs filed an opposition, and Richman filed a reply to such 2 motion. ECF Nos. 18, 19. On January 8, 2025, the Court heard oral argument on all motions 3 and took the matters under submission. ECF No. 25. After due consideration and for the 4 reasons discussed below, the motion to remand is GRANTED and the motion to transfer 5 or in the alternative, motion to dismiss is DENIED as moot. 6 I. BACKGROUND 7 In 2023, Plaintiffs completed and submitted a rental application (“Application”) to 8 apply for an apartment unit in a building operated by Richman. NOR, Exh. A (“Compl.”) 9 ¶¶ 14, 17. The Application notified applicants that Richman may screen for criminal 10 background and previous evictions. Id. ¶ 16. Richman did not provide a process for 11 Plaintiffs to indicate that they wished to receive a copy of any report prepared in connection 12 with their respective Applications, and it did not provide Plaintiffs with “a consent form or 13 disclosure with a box to check as required by the ICRAA” in connection with such reports. 14 Id. ¶ 22. Richman later processed Plaintiffs’ Application and requested investigative 15 consumer reports about each Plaintiff, obtaining at least two such reports about each 16 Plaintiff. Id. ¶¶ 19, 21. Richman did not provide Plaintiffs a copy of any such reports. Id. ¶ 17 23. 18 On August 5, 2024, Plaintiffs filed this lawsuit in the Superior Court of the State of 19 California, County of San Diego. NOR ¶ 1. In their Complaint, Plaintiffs assert three causes 20 of action: (1) violation of the ICRAA (Compl. ¶¶ 26-36); (2) invasion of privacy (Compl. 21 ¶¶ 37-43); and (3) false advertising (Compl. ¶¶ 44-48). As relief, Plaintiffs request (1) 22 general, compensatory, and punitive damages; (2) statutory damages; (3) interest; (4) 23 attorneys’ fees; (5) equitable relief and restitution; (6) declaratory judgment that Plaintiffs’ 24 Application and re-certification violates the ICRAA; (7) an injunction enjoining Richman 25 from violating the ICRAA or refusing to rent to Plaintiffs; and (8) a writ of mandate and 26 injunction requiring Richman to, among other things, comply with the ICRAA by including 27 in its rental application an option for prospective applicants to receive a copy of any 28 1 investigative consumer report and, if requested, providing the reports themselves. Compl., 2 Request for Relief. 3 II. LEGAL STANDARD 4 Federal courts are courts of limited jurisdiction. Gunn v. Minton, 568 U.S. 251, 256 5 (2013). In a case originally brought in state court, a defendant may remove the action to 6 federal court if there is federal subject matter jurisdiction. 28 U.S.C. § 1441(a) (“Except as 7 otherwise expressly provided by Act of Congress, any civil action brought in a State court 8 of which the district courts of the United States have original jurisdiction, may be removed 9 by the defendant or the defendants, to the district court of the United States for the district 10 and division embracing the place where such action is pending.”). 11 “Consistent with the limited jurisdiction of federal courts, the removal statute is 12 strictly construed against removal jurisdiction.” Audo v. Ford Motor Co., No. 3:18-cv- 13 00320-L-KSC, 2018 WL 3323244, at *1 (S.D. Cal. July 6, 2018) (citing Gaus v. Miles, 14 Inc., 980 F.2d 564, 566 (9th Cir. 1992)). Therefore, the “burden of establishing that 15 removal is proper” always lies with the defendant. Gaus, 980 F.2d at 566. If there is any 16 doubt as to the propriety of removal, the court shall reject federal subject matter 17 jurisdiction. Id.; see also Hansen v. Grp. Health Coop., 902 F.3d 1051, 1057 (9th Cir. 2018) 18 (“If a district court determines at any time that less than a preponderance of the evidence 19 supports the right of removal, it must remand the action to the state court.”). 20 Federal subject matter jurisdiction may arise based on federal question or diversity 21 jurisdiction. 28 U.S.C. §§ 1331, 1332(a). In the notice of removal, Defendant states that 22 this court has federal subject matter jurisdiction over the matter based on diversity 23 jurisdiction. NOR ¶¶ 9-12. Further, to satisfy § 1332, the matter in controversy must 24 exceed the sum or value of $75,000, exclusive of interests and costs. 28 U.S.C. § 1332(a). 25 Under 28 U.S.C. § 1446, a defendant removing a civil action from state to federal 26 district court must include “a short and plain statement of the grounds for removal,” 27 including as to the amount in controversy being met. 28 U.S.C. § 1446(a). Where a plaintiff 28 challenges the defendant’s allegation of jurisdiction under § 1332(a), § 1446 provides that 1 “removal of the action is proper on the basis of an amount in controversy asserted [in the 2 notice of removal] if the district court finds, by the preponderance of the evidence, that the 3 amount in controversy exceeds the amount specified in section 1332(a).” 28 U.S.C. § 4 1446(c)(2)(B); see Dart Cherokee Basin Operating Co., LLC v. Owens, 574 U.S. 81, 88 5 (2014). 6 In Dart, the Supreme Court recognized that this provision was added to § 1446 as 7 part of the Federal Courts Jurisdiction and Venue Clarification Act of 2011 to “clarify[] 8 the procedure in order when a defendant’s assertion of the amount in controversy is 9 challenged. In such a case, both sides submit proof and the court decides, by a 10 preponderance of the evidence, whether the amount-in-controversy requirement has been 11 satisfied.” Id. Even though Dart arose under the Class Action Fairness Act (“CAFA”), 12 other courts within this district have applied this framework to non-CAFA cases. See De 13 Villing v. Sabert Corp., No. EDCV18-2201 JGB (KKx), 2018 WL 6570868, at *2 (C.D. 14 Cal. Dec. 11, 2018) (noting that Dart interpreted 28 U.S.C.§ 1446

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Tillman v. Richman Property Services, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/tillman-v-richman-property-services-inc-casd-2025.