Scott Byler v. Mastec Services Company et al.

Summary

The United States District Court for the Central District of California granted Scott Byler’s motion to remand the case to Riverside Superior Court. The court held that, because Defendants disclaimed reliance on CAFA and conceded that the amount in controversy for Byler’s individual claims did not exceed $75,000 at the time of removal, federal diversity jurisdiction was lacking.

Holdings

1. The amount in controversy for Plaintiff's individual claims did not satisfy the $75,000 jurisdictional threshold, so federal diversity jurisdiction under § 1332(a) was lacking.
2. The court did not decide whether jurisdiction existed under CAFA because Defendants expressly disclaimed reliance on 28 U.S.C. § 1332(d).

Questions Presented

1. Whether federal jurisdiction existed under 28 U.S.C. § 1332(a) when the amount in controversy for Plaintiff's individual claims did not exceed $75,000.
2. Whether the court should address jurisdiction under the Class Action Fairness Act after Defendants disclaimed reliance on CAFA.

Disposition

remanded