Summary
The United States District Court for the Central District of California denied Plaintiff Angel Bazan’s motion to remand an employment-discrimination action against Sedgwick Claims Management Services, Inc. The court held that Sedgwick established complete diversity because it was incorporated in Illinois and its principal place of business, or nerve center, was in Memphis, Tennessee.
Topics
Practice areas
Questions Presented
- Whether the court had diversity subject-matter jurisdiction over the removed action.
- Whether Sedgwick established that its principal place of business was in Tennessee, rather than California, for purposes of complete diversity.
- Whether the court could consider Sedgwick's declaration and California Secretary of State Statement of Information over Bazan's hearsay, authentication, foundation, and speculation objections.
Holdings
- The court had diversity subject-matter jurisdiction because Bazan was a California resident, Sedgwick was incorporated in Illinois and had its principal place of business in Tennessee, and the parties did not dispute that the amount in controversy exceeded $75,000.
- Sedgwick's principal place of business was in Memphis, Tennessee.
- The court overruled Bazan's objections to the Statement of Information and the Jenkins Declaration and considered both in deciding the remand motion.
Key quotations
“where [Defendant’s]…officers direct, control, and coordinate the corporation’s activities [and]...where [Defendant] maintains its headquarters.” (559 U.S. at 93)
Factual background
Bazan, a California resident, sued Sedgwick after alleging that his employment with Walmart was terminated because of absences related to his bipolar disorder and that Sedgwick rejected paperwork supporting medical leave. Sedgwick was alleged to be incorporated in Illinois and to serve as Walmart's third-party administrator for disability and workers' compensation claims. Sedgwick submitted a declaration and a California Secretary of State Statement of Information showing that its executive functions, officers, directors, principal address, and corporate headquarters were in Memphis, Tennessee.
Procedural history
Bazan filed an eight-count complaint in Los Angeles County Superior Court on March 28, 2025. Sedgwick removed the action to the Central District of California the same day, asserting diversity jurisdiction. Bazan moved to remand, and the court denied the motion after overruling evidentiary objections to declarations and supporting corporate records.