Jennifer J. Walter v. Sterling Jewelers Inc.

Summary

The Central District of California granted Plaintiff Jennifer J. Walter’s motion to remand a putative wage-and-hour class action against Sterling Jewelers Inc. The court held that the defendant failed to establish by a preponderance of the evidence that more than $5 million was in controversy under the Class Action Fairness Act because its violation-rate assumptions were unsupported by the complaint or evidence. The court denied the defendant’s motion to dismiss as moot and remanded the action to Los Angeles County Superior Court.

Holdings

1. Defendant failed to establish by a preponderance of the evidence that more than $5 million was in controversy, so the action had to be remanded.
2. The phrase "systematic pattern" alone does not support any particular assumed violation rate for calculating the amount in controversy.
3. Defendant's motion to dismiss was denied as moot after the action was remanded to state court.

Questions Presented

1. Whether defendant established by a preponderance of the evidence that more than $5 million was in controversy for purposes of CAFA jurisdiction.
2. Whether defendant could establish the amount in controversy through assumed violation rates unsupported by the complaint or additional evidence.
3. Whether defendant's motion to dismiss remained justiciable after remand.

Disposition

remanded