Greg Anderson v. Louis Vuitton North America, Inc.

Summary

The United States District Court for the Central District of California denied Plaintiff Greg Anderson’s motion to remand, holding that Defendants established complete diversity and an amount in controversy exceeding $75,000. The court also denied Defendant Louis Vuitton USA Inc.’s motion to compel arbitration and dismiss or stay the action because Plaintiff’s alleged sexual-harassment claim was a nonfrivolous claim potentially covered by the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act. The court did not decide whether a valid arbitration agreement existed.

Holdings

1. Defendants established complete diversity because LVUSA and LVNA were Delaware corporations with principal places of business in New York, while the undisputed facts and Plaintiff's California residence supported the conclusion that Plaintiff was domiciled and therefore a citizen of California.
2. Defendants established by a preponderance of the evidence that the amount in controversy exceeded $75,000.
3. A plaintiff need only plead a nonfrivolous claim relating to conduct alleged to constitute sexual harassment to invoke the EFAA; the court should reserve the claim's sufficiency and merits for an appropriate merits proceeding rather than deciding them on a motion to compel arbitration.
4. The court did not need to decide whether the parties entered into a valid arbitration agreement because the EFAA issue was dispositive of the motion to compel arbitration.

Questions Presented

1. Whether Defendants established complete diversity of citizenship for purposes of removal.
2. Whether Defendants established by a preponderance of the evidence that the amount in controversy exceeded $75,000.
3. Whether the alleged sexual-harassment claim constituted a nonfrivolous claim relating to conduct alleged to constitute sexual harassment under the EFAA, thereby precluding enforcement of a predispute arbitration agreement as to the case.
4. Whether the court should decide the validity of the alleged arbitration agreement after determining that the EFAA applied.

Disposition

other