Antonia Anaya v. Target Corporation et al.

Summary

The United States District Court for the Central District of California denies Plaintiff Antonia Anaya’s motion to remand, holding that Target Corporation’s removal was timely and that diversity jurisdiction existed despite the fictitious defendant. The court disregards the citizenship of “Manny Doe” under 28 U.S.C. § 1441(b)(2) because the complaint contained no particularized allegations identifying that defendant. The court also orders Plaintiff and her counsel to show cause why they should not be sanctioned under Federal Rule of Civil Procedure 16(f) for repeated violations of court orders and rules.

Holdings

1. Removal was timely because the initial complaint did not make federal jurisdiction apparent, and Target removed within thirty days after receiving post-complaint documents that made the amount in controversy and Plaintiff's citizenship sufficiently clear.
2. The court had diversity jurisdiction because Plaintiff was a California citizen, Target was a Minnesota citizen, the amount in controversy exceeded $75,000, and Manny Doe's citizenship was required to be disregarded under 28 U.S.C. § 1441(b)(2).
3. Plaintiff and her counsel were ordered to show cause why sanctions should not be imposed under Federal Rule of Civil Procedure 16(f) for repeated violations of court orders and related procedural requirements.

Questions Presented

1. Whether Target's removal was timely under 28 U.S.C. § 1446(b).
2. Whether the district court had diversity subject-matter jurisdiction despite the fictitious defendant Manny Doe.
3. Whether Plaintiff and her counsel should be ordered to show cause why they should not be sanctioned for repeated violations of court orders.

Disposition

other