Michael Sandoval v. Little Caesar Enterprises, Inc.

Summary

The United States District Court for the Central District of California sua sponte remanded the case to the Superior Court of California, County of Orange. The court held that the First Amended Complaint eliminated federal-question jurisdiction and that the defendant had not shown by a preponderance of the evidence that the amount in controversy exceeded $75,000 for diversity jurisdiction. The order was issued as a civil minutes order on April 16, 2025.

Holdings

1. When a plaintiff amends the complaint after removal to eliminate all federal-law claims, the district court loses federal-question jurisdiction over the remaining state-law claims.
2. Where the complaint does not expressly allege more than $75,000 in controversy, the removing defendant must prove by a preponderance of the evidence that the amount-in-controversy requirement is satisfied.
3. On the record presented, the amount in controversy was $66,000, not more than $75,000, because the court included the $50,000 limit on injunctive relief, $12,000 in potential statutory damages, and $4,000 for deterrence, but declined to include speculative civil penalties or attorney's fees.
4. When a federal district court lacks subject matter jurisdiction over a removed action, it must remand the action to state court.

Questions Presented

1. Whether plaintiff's post-removal amended complaint, which eliminated the federal claim, left federal-question jurisdiction in the district court.
2. Whether defendant established by a preponderance of the evidence that the amount in controversy exceeded $75,000 for purposes of diversity jurisdiction.
3. Whether the district court was required to remand the action for lack of subject matter jurisdiction.

Disposition

remanded