Jauregui v. Roadrunner Transportation Services, Inc., No. 22-55058 (9th Cir. 2022)
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A putative class action against Roadrunner on behalf of all of Roadrunner’s California current and former hourly workers, alleged violations of California wage and hour laws. Roadrunner removed the case to federal court, invoking the Class Action Fairness Act (CAFA), 28 U.S.C. 1711. The district court found that Roadrunner failed to establish the requisite $5 million minimum amount in controversy, and remanded the case to state court.
The Ninth Circuit reversed The district court erred in imposing a presumption against CAFA jurisdiction, imposing “an inappropriate demand of certitude from Roadrunner.” Because the plaintiff contested removal, Roadrunner was required to show the amount in controversy by a preponderance of the evidence. Roadrunner offered substantial evidence and identified assumptions to support its valuation of each claim. The district court erred in assigning a $0 value to five claims where it disagreed with Roadrunner’s calculations. Nothing in CAFA or caselaw “compels such a draconian response when the district court disagrees with a single assumption underlying the claim valuation.” The CAFA amount in controversy requirement was met; using the lowest hourly wage rate identified by the court, the minimum wage claim was reasonably valued at $4.5 million, plus the $2.1 million for two claims accepted by the district court.
Court Description: Amount in Controversy / Class Action Fairness Act The panel reversed the district court’s order that remanded a class action to California state court after it determined that the $5 million amount in controversy requirement of the Class Action Fairness Act (“CAFA”) was not met. The plaintiff filed a putative class action against Roadrunner Transportation Services on behalf of all Roadrunner and former California hourly workers, alleging violations of California labor law, primarily wage and hour violations. Roadrunner removed the case to federal court, invoking jurisdiction under CAFA. Plaintiff responded with a motion to remand for lack of jurisdiction. The district court found that Roadrunner failed to meet its burden to establish the requisite $5 million minimum for the amount in controversy, and remanded to state court. The panel held that the district court erred in imposing – both explicitly and in its analysis – a presumption against CAFA jurisdiction. Presumably because of this, latent throughout the order was an inappropriate demand of certitude from Roadrunner over its assumptions used in calculating the amount in controversy. The panel also held that the district court erred in how it approached the amount in controversy analysis. Because plaintiff contested removal, Roadrunner was required to JAUREGUI V. ROADRUNNER TRANSP. SERV. 3 show the amount in controversy by a preponderance of the evidence. Roadrunner offered substantial evidence and identified assumptions to support its valuation of each of the various claims in this case. The district court erred in assigning a $0 value for the amount in controversy for each of the five claims where it disagreed with Roadrunner’s calculations. The panel held that nothing in CAFA or caselaw compels such a draconian response when the district court disagrees with a single assumption underlying the claim valuation. The panel held that the CAFA amount in controversy requirement was met. Using the lowest hourly wage rate identified by the district court, the minimum wage claim was reasonably valued at $4.5 million. Added to the $2.1 million for the two other claims accepted by the district court, that would be more than enough to establish jurisdiction under CAFA, without even considering any of the other four claims that the district court also zeroed-out. The panel remanded to the district court for further proceedings.
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