Chavez v. JPMorgan Chase & Co., No. 16-55957 (9th Cir. 2018)
Annotate this CaseThe Ninth Circuit held that it had subject matter jurisdiction in this case because 28 U.S.C. 1332's amount-in-controversy requirement was met when the case was removed. The panel clarified that the amount in controversy is not limited to damages incurred prior to removal—for example, it is not limited to wages a plaintiff-employee would have earned before removal (as opposed to after removal). Rather, the panel explained that the amount in controversy is determined by the complaint operative at the time of removal and encompasses all relief a court may grant on that complaint if the plaintiff is victorious. In this case, the amount-in-controversy requirement was easily satisfied and the panel had subject matter jurisdiction over the action.
Court Description: Diversity Jurisdiction. The panel held that the amount-in-controversy requirement for diversity jurisdiction under 28 U.S.C. § 1332 was satisfied. Elsa Chavez sued her former employer in California state court, and the employer removed to federal district court on the basis of diversity jurisdiction. The panel held that the amount in controversy was not limited to damages incurred prior to removal – for example, it was not limited to wages a plaintiff-employee would have earned before removal (as opposed to after removal). The panel further held that the amount in controversy was determined by the complaint operative at the time of removal and encompassed all relief a court may grant on that complaint if the plaintiff was victorious. The panel applied the standard and concluded that the amount-in-controversy standard was easily satisfied in this case. The panel reviewed the merits of the district court’s summary judgment decision in a concurrently filed memorandum disposition. CHAVEZ V. JPMORGAN CHASE 3
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