Michael Sandoval v. Visionworks of America, Inc. et al.

Summary

The court sua sponte remands the action to the Superior Court of California, County of Orange, because the defendant did not establish that the amount in controversy satisfied the requirements for diversity jurisdiction. The court concludes that the plaintiff's claimed statutory damages, injunctive relief, and attorneys' fees were insufficiently supported by factual evidence to meet the $75,000 threshold. The underlying action concerns alleged website accessibility barriers affecting a visually impaired plaintiff under California's Unruh Act.

Holdings

1. Defendant failed to establish by a preponderance of the evidence that the amount in controversy exceeded $75,000.
2. The action was required to be remanded to the Superior Court of California, County of Orange, because the district court lacked subject matter jurisdiction.

Questions Presented

1. Whether the district court had diversity jurisdiction when Plaintiff alleged an amount in controversy of $74,999 and Defendant failed to provide facts showing that statutory damages, injunctive relief, or attorney fees would cause the amount in controversy to exceed $75,000.
2. Whether the action should be remanded sua sponte for lack of subject matter jurisdiction.

Disposition

remanded