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United States Court of Appeals for the Ninth Circuit
February 7, 2022, Argued and Submitted, San Francisco, California; March 17, 2022, Filed
VANDYKE, Circuit Judge:
We are asked in this case to review the district court's order remanding a class action to California state court after it determined that the $5 million amount in controversy requirement of the Class Action Fairness Act was not met. Because the district court erred in its amount in controversy analysis by assigning a $0 valuation to several claims, we reverse and remand.
Plaintiff Griselda Jauregui filed a putative class action in California Superior Court against Defendant Roadrunner Transportation Services (Roadrunner) on behalf of [*4] all Roadrunner current and former California hourly workers. The complaint alleged numerous violations of California labor law focused primarily on wage and hour violations.3 Roadrunner removed the case to federal court, invoking Class Action Fairness Act (CAFA) jurisdiction. Plaintiff responded with a motion to remand, arguing that the district court lacked jurisdiction under CAFA because the requisite $5 million minimum for the amount in controversy had not been met.4 As authorized under CAFA, Roadrunner responded with "summary judgment style evidence" to establish the amount in controversy. Roadrunner relied primarily on the declaration of its senior payroll lead who concluded that, based on the company's payroll data and Plaintiff's allegations, the amount in controversy was $14,780,377.06.5
The district court found that [*5] Roadrunner failed to meet its burden and remanded the case to the state court. The court reached this conclusion after independently evaluating Roadrunner's amount in controversy calculations for each of the seven alleged violations. The court found that Roadrunner had sufficiently demonstrated the claimed amount in controversy for only two of the claims (overtime claims and meal and rest break claims). For the remaining five claims, the court found that Roadrunner erred in its calculation of the amount in controversy, mostly because of reliance on incorrect variables or assumptions. Critical for our purposes, the district court assigned a $0 value for the amount in controversy for each of the five claims where it disagreed with Roadrunner's calculations. As a result, the district court concluded that the amount in controversy was only $2.1 million—the total for the two claims in which the district court agreed with Roadrunner's calculations. Because this was less than the $5 million CAFA threshold, the court granted Plaintiff's motion to remand. Roadrunner timely appealed.6
Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.
2022 U.S. App. LEXIS 6932 *; 28 F.4th 989
GRISELDA JAUREGUI, individually, and on behalf of other members of the general public similarly situated, Plaintiff-Appellee, v. ROADRUNNER TRANSPORTATION SERVICES, INC., an unknown business entity, Defendant-Appellant.
Prior History: [*1] Appeal from the United States District Court for the Central District of California. D.C. No. 2:21-cv-04657-RGK-PD. R. Gary Klausner, District Judge, Presiding.
Jauregui v. Roadrunner Transp. Servs., Inc., 2021 U.S. Dist. LEXIS 171406, 2021 WL 4100286 (C.D. Cal., Sept. 8, 2021)
Disposition: REVERSED and REMANDED.
amount in controversy, district court, assumptions, removal, calculations, assigning, estimate, class action, federal court, minimum wage, valuation, cases
Civil Procedure, Special Proceedings, Class Actions, Class Action Fairness Act, Evidence, Burdens of Proof, Preponderance of Evidence, Appeals, Standards of Review, De Novo Review, Removal, Specific Cases Removed, Diversity of Citizenship, Allocation, Diversity Jurisdiction, Amount in Controversy, Determination