Way v. Valero Energy Corporation

CourtDistrict Court, M.D. Louisiana
DecidedFebruary 27, 2025
Docket3:24-cv-00416
StatusUnknown

This text of Way v. Valero Energy Corporation (Way v. Valero Energy Corporation) is published on Counsel Stack Legal Research, covering District Court, M.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Way v. Valero Energy Corporation, (M.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF LOUISIANA

ANTHONY WAY, et al. CIVIL ACTION

VERSUS NO. 24-416-SDD-SDJ

VALERO ENERGY CORPORATION, et al.

NOTICE

Please take notice that the attached Magistrate Judge’s Report has been filed with the Clerk of the United States District Court.

In accordance with 28 U.S.C. § 636(b)(1), you have 14 days after being served with the attached Report to file written objections to the proposed findings of fact, conclusions of law, and recommendations therein. Failure to file written objections to the proposed findings, conclusions, and recommendations within 14 days after being served will bar you, except upon grounds of plain error, from attacking on appeal the unobjected-to proposed factual findings and legal conclusions of the Magistrate Judge which have been accepted by the District Court.

ABSOLUTELY NO EXTENSION OF TIME SHALL BE GRANTED TO FILE WRITTEN OBJECTIONS TO THE MAGISTRATE JUDGE’S REPORT.

Signed in Baton Rouge, Louisiana, on February 27, 2025.

S

SCOTT D. JOHNSON UNITED STATES MAGISTRATE JUDGE UNITED STATES DISTRICT COURT

MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION

Before the Court is a Motion to Remand (R. Doc. 37) filed by Plaintiffs on June 26, 2024. Defendant Valero Refining-New Orleans opposes this Motion (R. Doc. 68). With leave of Court, Plaintiffs filed a Reply Memorandum in support of their Motion to Remand (R. Doc. 72). For the reasons set forth below, the Court finds that it has jurisdiction over this matter and recommends that Plaintiff’s Motion to Remand (R. Doc. 37) be denied. I. BACKGROUND Plaintiffs filed this cause of action on or about April 12, 2024, in the Nineteenth Judicial District Court for the Parish of East Baton Rouge, State of Louisiana.1 Plaintiffs’ claims arise from an alleged incident that occurred on April 29, 2023, while Plaintiff Anthony Way was working as a loader operator in the coker unit of the Valero St. Charles Refinery in Norco, Louisiana.2 During the release of hot slurry into the designated coke pit area, the slurry overflowed the coke pit area, covering Way, who was working in that area at the time.3 As a result, Way “suffered catastrophic burns to over 68% of his body.”4

1 R. Doc. 1-2 at 1. 2 Id. at 5, 6 ¶¶ 9, 13. 3 Id. at 7 ¶¶ 17-18. 4 Id. at 8 ¶ 20. On May 29, 2024, Valero removed this case to federal court based on diversity jurisdiction pursuant to 28 U.S.C. § 1332(a).5 In their Notice of Removal, Valero asserts that diversity jurisdiction exists because the amount in controversy is met and all properly joined parties are completely diverse.6 Specifically, Valero argues that Darryl Lessard; Performance Contractors, Inc.; MMR Group, Inc.; ISC Constructors, LLC; and Repcon, Inc., all of which are Louisiana

citizens, are improperly joined.7 Following removal, Plaintiff filed the instant Motion to Remand (R. Doc. 37). II. LAW AND ANALYSIS A. Removal Standard A defendant may remove “any civil action brought in a State court of which the district courts of the United States have original jurisdiction.” 28 U.S.C. § 1441(a). When original jurisdiction is based on diversity of citizenship, the cause of action must be between “citizens of different States,” and the amount in controversy must exceed the “sum or value of $75,000, exclusive of interest and costs.” 28 U.S.C. § 1332(a).

Subject matter jurisdiction must exist at the time of removal to federal court, based on the facts and allegations contained in the complaint. St. Paul Reinsurance Co., Ltd. v. Greenberg, 134 F.3d 1250, 1253 (5th Cir. 1998). In removed actions, diversity of citizenship must exist both at the time of filing in state court and at the time of removal to federal court. Coury v. Prot, 85 F.3d 244, 249 (5th Cir. 1996). The removing party has the burden of proving federal diversity jurisdiction. Garcia v. Koch Oil Co. of Tex. Inc., 351 F.3d 636, 638 (5th Cir. 2003). The removal statute is strictly construed, and any doubt as to the propriety of removal should be resolved in

5 R. Doc. 1 at 10. 6 Id. at 10-21. 7 Id. at 14-17. favor of remand. Manguno v. Prudential Prop. & Cas. Ins. Co., 276 F.3d 720, 723 (5th Cir. 2002). Remand is proper if at any time the court lacks subject matter jurisdiction. See 28 U.S.C. § 1447(c). B. Whether This Court Has Diversity Jurisdiction The Court first turns to the question of whether it has diversity jurisdiction over this matter

pursuant to 28 U.S.C. § 1332. 28 U.S.C. § 1441 specifies that “[a] civil action removable solely on the basis of the jurisdiction under section 1332(a) of this title may not be removed if any of the parties in interest properly joined and served as defendants is a citizen of the State in which such action is brought.” 28 U.S.C. § 1441(b)(2). Here, the Parties do not dispute that Darryl Lessard; Performance Contractors, Inc.; MMR Group, Inc.; ISC Constructors, LLC; and Repcon, Inc., are citizens of Louisiana. The question then is whether, as argued by Valero, these parties are improperly joined. 1. Legal Standard “Ordinarily, diversity jurisdiction requires complete diversity—if any plaintiff is a citizen

of the same State as any defendant, then diversity jurisdiction does not exist.” Flagg v. Stryker Corp., 819 F.3d 132, 136 (5th Cir. 2016). But, if the plaintiff improperly joins a non-diverse defendant, then the court may disregard the citizenship of that defendant, dismiss them from the litigation, and exercise subject matter jurisdiction over the remaining diverse defendants. See Williams v. Homeland Ins. Co. of N.Y., 18 F.4th 806, 810 n.5 (5th Cir. 2021) (“[T]he proper mechanism of handling an improperly joined party is to dismiss it, not send it to another court to decide the merits.”). “The party seeking removal bears a heavy burden of proving that the joinder of the in-state party was improper.” Smallwood v. Ill. Cent. R.R. Co., 385 F.3d 568, 574 (5th Cir. 2004). The Fifth Circuit has “recognized two ways to establish improper joinder: ‘(1) actual fraud in the pleading of jurisdictional facts, or (2) inability of the plaintiff to establish a cause of action against the non-diverse party in state court.’” Id. at 573, quoting Travis v. Irby, 326 F.3d 644, 646- 47 (5th Cir. 2003).

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Way v. Valero Energy Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/way-v-valero-energy-corporation-lamd-2025.