Xie v. Wal-Mart Associates, Inc.

CourtDistrict Court, N.D. California
DecidedApril 17, 2025
Docket4:25-cv-00091
StatusUnknown

This text of Xie v. Wal-Mart Associates, Inc. (Xie v. Wal-Mart Associates, Inc.) 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
Xie v. Wal-Mart Associates, Inc., (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 ZHENXING XIE, Case No. 25-cv-00091-HSG

8 Plaintiff, ORDER REMANDING CASE 9 v. Re: Dkt. No. 8, 12

10 WAL-MART ASSOCIATES, INC., 11 Defendant.

12 13 Pending before the Court is Plaintiff Zhenxing Xie’s motion to remand, briefing for which 14 is complete. Dkt. Nos. 12 (“Mot.”), 18 (“Opp.”), 19 (“Reply”). The Court finds this matter 15 appropriate for disposition without oral argument and the matter is deemed submitted. See Civil 16 L.R. 7-1(b). For the reasons discussed below, the Court GRANTS the motion. 17 I. BACKGROUND 18 Mr. Xie began working for Defendant Walmart Associates, Inc. (“Walmart”) as a Senior 19 Product Manager in August 2022. Dkt. No. 1-2 (“Compl.”). Mr. Xie’s father passed away on 20 March 29, 2023, and he was granted bereavement leave. Id. at 6. When Mr. Xie returned to work 21 on May 1, 2023, he alleges that he “experienced a sudden increase in workload and unreasonable 22 deadlines for assignments.” Id. When Mr. Xie discussed his concerns with a supervisor, 23 Defendant Mariam Tareen, and informed Ms. Tareen that his wife was pregnant, she allegedly 24 “told Plaintiff that a former employee of Wal-mart was terminated for taking a fraudulent medical 25 leave” and “told Plaintiff that she . . . [had] not tak[en] leave when her kids were small.” Id. at 14. 26 According to Mr. Xie, Ms. Tareen also “suggested” that Plaintiff should not use the pregnancy as 27 an “excuse to take days off from work.” Id. 1 loss of sleep, and exhaustion. When he informed his supervisors about this distress, they allegedly 2 reported him to Walmart’s Global Security Department as a possible workplace threat. Id. From 3 May 31, 2023 to December 30, 2023, Mr. Xie took approved medical leave. During his approved 4 leave, Ms. Tareen informed Plaintiff that Walmart was searching for his replacement and that his 5 role would be terminated. Id. at 15. Mr. Xie initially informed Walmart that he could return to 6 work in January 2024 and then requested parental leave through May 2024. Walmart granted Mr. 7 Xie’s parental leave request, but in February 2024—during Mr. Xie’s approved parental leave— 8 Walmart informed him that his role would be terminated thirty days after his parental leave 9 concluded. Mr. Xie alleges that he repeatedly informed Walmart that he could return to work at 10 the conclusion of his approved parental leave. Id. at 16. Mr. Xie unsuccessfully applied for other 11 jobs at Walmart, submitted internal discrimination complaints, and was eventually terminated on 12 June 26, 2024, which was exactly one month after his parental leave concluded. 13 In November 2024, Mr. Xie filed the operative complaint in San Mateo County Superior 14 Court. As relevant here, Mr. Xie alleges that Defendants (1) committed harassment on the basis of 15 disability in violation of California’s Fair Employment and Housing Act (FEHA), (2) intentionally 16 inflicted emotional distress, and (3) negligently inflicted emotional distress. See Compl. at 31–35. 17 In January 2025, Defendants removed this matter to federal court on the basis of diversity 18 jurisdiction under 28 U.S.C. § 1332. Mr. Xie now moves to remand, arguing that removal is 19 improper because both he and Defendant Tareen are residents of California. Mot. at 6. 20 Defendants oppose, asserting that Ms. Tareen was fraudulently joined as a defendant to defeat 21 diversity jurisdiction. 22 II. LEGAL STANDARD 23 A defendant may remove a state court action to federal court on the basis of diversity 24 jurisdiction. See 28 U.S.C § 1441; see also Rodriguez v. AT&T Mobility Servs. LLC, 728 F.3d 25 975, 977 (9th Cir. 2013) (“A defendant may remove to federal district court an action first brought 26 in state court when the district court would have original jurisdiction.”). Diversity jurisdiction 27 exists where the matter in controversy exceeds $75,000 and the dispute is between citizens of 1 remand the action because it has no subject-matter jurisdiction to decide the case.” ARCO Envtl. 2 Remediation, L.L.C. v. Dep’t of Health & Envtl. Quality of Mont., 213 F.3d 1108, 1113 (9th Cir. 3 2000). On a motion to remand, federal courts must presume that a cause of action lies beyond its 4 subject matter jurisdiction, Hunter v. Philip Morris USA, 582 F.3d 1039, 1042 (9th Cir. 2009), and 5 must reject federal jurisdiction “if there is any doubt as to the right of removal in the first 6 instance,” Gaus v. Miles, Inc., 980 F.2d 564, 566 (9th Cir. 1992). The removing party bears the 7 burden of establishing federal jurisdiction. See id. at 566–67. 8 III. DISCUSSION 9 The parties agree that Plaintiff Xie and Defendant Tareen are both citizens of California. 10 Mot. at 6. Section 1332, which enables federal courts to exercise jurisdiction over suits “between . 11 . . citizens of different States,” only applies when “the citizenship of each plaintiff is diverse from 12 the citizenship of each defendant.” Caterpillar Inc. v. Lewis, 519 U.S. 61, 68 (1996). At issue 13 here, then, is whether Ms. Tareen was fraudulently joined, such that her citizenship does not 14 destroy the parties’ diversity. 15 A. Legal Standard for Fraudulent Joinder 16 “In determining whether there is complete diversity, district courts may disregard the 17 citizenship of a non-diverse defendant who has been fraudulently joined.” Grancare, LLC v. 18 Thrower ex rel. Mills, 889 F.3d 543, 548 (9th Cir. 2018). Joinder is fraudulent “[i]f the plaintiff 19 fails to state a cause of action against a resident defendant, and the failure is obvious according to 20 the settled rules of the state.” Id. (citations omitted). Fraudulent joinder is established on that 21 ground if the individuals “joined in the action cannot be liable on any theory.” Id. (citation 22 omitted). However, “if there is a possibility that a state court would find that the complaint states 23 a cause of action against any of the resident defendants, the federal court must find that the joinder 24 was proper and remand the case to the state court.” Id. (emphasis in original) (citation omitted). 25 In other words, joinder is only fraudulent if it is “obvious according to the settled rules of the state 26 that [Plaintiff Xie] has failed to state a claim against [Defendant Tareen].” Hunter, 582 F.3d at 27 1046. 1 evidence or arguments that a plaintiff could not possibly prevail on its claims against the allegedly 2 fraudulently joined defendant,” including where “a plaintiff is barred by the statute of limitations 3 from bringing claims against that defendant.” Grancare, 889 F.3d at 548. By contrast, fraudulent 4 joinder is not established where “a defendant raises a defense that requires a searching inquiry into 5 the merits of the plaintiff’s case, even if that defense, if successful, would prove fatal.” Id. at 548– 6 49 (citing Hunter, 582 F.3d at 1046). There is a “general presumption against fraudulent joinder,” 7 and defendants who assert that a party is fraudulently joined carry a “heavy burden,” Hunter, 582 8 F.3d at 1046, particularly since “[f]raudulent joinder must be proven by clear and convincing 9 evidence,” Hamilton Materials, Inc. v. Dow Chem. Corp.,

Related

Caterpillar Inc. v. Lewis
519 U.S. 61 (Supreme Court, 1996)
Cynthia Lawler v. Montblanc North America, LLC
704 F.3d 1235 (Ninth Circuit, 2013)
Hunter v. Philip Morris USA
582 F.3d 1039 (Ninth Circuit, 2009)
Hamilton Materials, Inc. v. Dow Chemical Corp.
494 F.3d 1203 (Ninth Circuit, 2007)
Lyle v. Warner Brothers Television Productions
132 P.3d 211 (California Supreme Court, 2006)
Grancare v. Ruth Thrower
889 F.3d 543 (Ninth Circuit, 2018)
Ludovico v. Kaiser Permanente
57 F. Supp. 3d 1176 (N.D. California, 2014)
Freitag v. Ayers
468 F.3d 528 (Ninth Circuit, 2006)

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Xie v. Wal-Mart Associates, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/xie-v-wal-mart-associates-inc-cand-2025.