Michael Moore v. Saia Motor Freight Line, LLC

Summary

The United States District Court for the Central District of California denied Michael Moore’s motion to remand a putative class action against Saia Motor Freight Line, LLC. The court held that minimal diversity existed and that the defendant established, by a preponderance of the evidence, more than $5 million in controversy under the Class Action Fairness Act. The court calculated approximately $5.8 million based on alleged meal-period premiums, rest-break premiums, and waiting-time penalties.

Holdings

1. An allegation that Plaintiff resides in California was sufficient in this case to establish minimal diversity for purposes of CAFA jurisdiction.
2. Defendant established by a preponderance of the evidence that more than $5 million was in controversy under CAFA.
3. The court declined to reduce the amount in controversy based on the dismissal of certain claims or the possibility of a valid preemption defense, because CAFA jurisdiction is assessed at the time of removal and a defense that might reduce recovery does not eliminate jurisdiction.

Questions Presented

1. Whether minimal diversity under CAFA was established when the removal allegations stated that Plaintiff resided in California.
2. Whether Defendant established by a preponderance of the evidence that the aggregate amount in controversy exceeded CAFA's $5 million threshold.
3. Whether dismissal or possible preemption of certain claims required reducing the amount in controversy for purposes of CAFA jurisdiction.

Disposition

other