Tim McVay v. Target; Target Corporation; and Does 1 to 100, inclusive

CourtDistrict Court, E.D. California
DecidedSeptember 26, 2025
Docket2:25-cv-00168
StatusUnknown

This text of Tim McVay v. Target; Target Corporation; and Does 1 to 100, inclusive (Tim McVay v. Target; Target Corporation; and Does 1 to 100, inclusive) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tim McVay v. Target; Target Corporation; and Does 1 to 100, inclusive, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 TIM MCVAY,

12 Plaintiff, No. 2:25-cv-00168-TLN-CSK

13 14 v. ORDER TARGET; TARGET CORPORATION; 15 and DOES 1 to 100, inclusive, 16 Defendants. 17 18 This matter is before the Court on Plaintiff Tim McVay’s (“Plaintiff”) Motion to Remand. 19 (ECF No. 10.) Defendant Target Corporation (“Defendant”) filed an opposition. (ECF No. 14.) 20 Plaintiff did not file a reply. Also before the Court is Plaintiff’s Application for Leave to File an 21 Amended Complaint. (ECF No. 11.) Defendant filed an opposition. (ECF No. 15.) Plaintiff did 22 not file a reply. For the reasons set forth below, Plaintiff’s Motion to Remand and Application 23 for Leave to File an Amended Complaint are DENIED. 24 /// 25 /// 26 /// 27 28 1 I. FACTUAL AND PROCEDURAL BACKGROUND 2 This is a premises liability case in which Plaintiff alleges he sustained injuries from a slip 3 and fall incident (“the Subject Incident”) at Defendant’s store located in Elk Grove, California on 4 January 19, 2022. (ECF No. 1 at 7.) On January 18, 2024, Plaintiff filed a complaint in 5 Sacramento Superior Court alleging: (1) general negligence and (2) premises liability. (Id. at 6.) 6 Plaintiff alleges he suffered: (1) loss of wages; (2) hospital and medical expenses; (3) general 7 damages; (4) loss of earning capacity; and (5) other damages according to proof. (Id.) On 8 January 13, 2025, Defendant removed the action to this Court based on diversity jurisdiction. 9 (ECF No. 1.) On February 12, 2025, Plaintiff filed the instant Motion to Remand and Application 10 for Leave to File an Amended Complaint. (ECF Nos. 10, 11.) 11 II. STANDARD OF LAW 12 A civil action brought in state court, over which the district court has original jurisdiction, 13 may be removed by the defendant to federal court in the judicial district and division in which the 14 state court action is pending. 28 U.S.C. § 1441(a). The district court has original jurisdiction 15 over civil actions between citizens of different states in which the alleged damages exceed 16 $75,000. 28 U.S.C. § 1332(a)(1). The party asserting federal jurisdiction bears the burden of 17 proving diversity. Lew v. Moss, 797 F.2d 747, 749 (9th Cir. 1986) (citing Resnik v. La Paz Guest 18 Ranch, 289 F.2d 814, 819 (9th Cir. 1961)). Diversity is determined as of the time the complaint 19 is filed and removal effected. Strotek Corp. v. Air Transp. Ass’n of Am., 300 F.3d 1129, 1131 20 (9th Cir. 2002). Removal statutes are to be strictly construed against removal. Gaus v. Miles, 21 Inc., 980 F.2d 564, 566 (9th Cir. 1992) (overruled on other grounds in Dart Cherokee Basin 22 Operating Co., LLC v. Owens, 574 U.S. 81, 87–89 (2014)). 23 The amount in controversy is determined by reference to the complaint itself and includes 24 the amount of damages in dispute, as well as attorney’s fees, if authorized by statute or contract. 25 Kroske v. U.S. Bank Corp., 432 F.3d 976, 980 (9th Cir. 2005). Where the complaint does not 26 pray for damages in a specific amount, the defendant must prove by a preponderance of the 27 evidence that the amount in controversy exceeds $75,000. Singer v. State Farm Mut. Auto. Ins. 28 Co., 116 F.3d 373, 376 (9th Cir. 1997) (citing Sanchez v. Monumental Life Ins. Co., 102 F.3d 1 398, 404 (9th Cir. 1996)). If the amount is not facially apparent from the complaint, the Court 2 may “require parties to submit summary-judgment-type evidence relevant to the amount in 3 controversy at the time of removal.” Id. (citing Allen v. R & H Oil & Gas Co., 63 F.3d 1326, 4 1335–36 (5th Cir. 1995)). 5 Removal based on diversity requires that the citizenship of each plaintiff be diverse from 6 the citizenship of each defendant (i.e., complete diversity). Caterpillar Inc. v. Lewis, 519 U.S. 61, 7 68 (1996). A corporation is a citizen of any state in which it is incorporated and any state in 8 which it maintains its principal place of business. 28 U.S.C. § 1332(c)(1). An individual 9 defendant’s citizenship is determined by the state in which they are domiciled. Weight v. Active 10 Network, Inc., 29 F. Supp. 3d 1289, 1292 (S.D. Cal. 2014). The citizenship of defendants sued 11 under fictitious names shall be disregarded when determining removal based on federal diversity 12 jurisdiction. 28 U.S.C. § 1441(b)(1). 13 III. ANALYSIS 14 Plaintiff argues this action should be remanded because complete diversity does not exist 15 as Defendant’s employees “potentially responsible” for causing the Subject Incident — Doe 16 Defendants — are California residents. (ECF No. 10 at 5.) Plaintiff further argues Defendant 17 failed to provide any admissible evidence in support of its contention that the amount in 18 controversy exceeds $75,000. (Id.) The Court considers each argument in turn. 19 A. Diversity of Citizenship 20 Plaintiff contends he is a citizen of California as are Doe Defendants. (Id. at 7.) Plaintiff 21 argues courts should consider Doe Defendants’ citizenship especially “when a named defendant 22 knew or should have known the fictitious defendant’s identity because that defendant employed 23 the fictitiously named defendant.” (Id. at 8 (citing Sandoval v. Republic Servs., Inc., No. 2:18– 24 CV–01224–ODW(KSX), 2018 WL 1989528, at *3 (C.D. Cal. Apr. 24, 2018)).) 25 In opposition, Defendant argues, for the purposes of removal jurisdiction, “the citizenship 26 of defendants sued under fictitious names shall be disregarded.” (ECF No. 14 at 4 (citing 28 27 U.S.C. § 1441 (b)).) Further, Defendant argues even when courts have considered the citizenship 28 of a Doe defendant on a motion to remand, the Doe defendant was specifically identified. (Id. at 1 5.) Defendant contends Plaintiff has not taken any action to even attempt to identify the alleged 2 Doe Defendants, let alone provide any physical description or other information to identify the 3 Doe Defendants. (Id. at 6.) 4 “In determining whether a civil action is removable on the basis of the jurisdiction under 5 section 1332(a) of this title, the citizenship of defendants sued under fictitious names shall be 6 disregarded.” 28 U.S.C § 1441(b)(1).

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Tim McVay v. Target; Target Corporation; and Does 1 to 100, inclusive, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tim-mcvay-v-target-target-corporation-and-does-1-to-100-inclusive-caed-2025.