Nhi Vo v. AB Car Rental Services, Inc. et al.

Summary

The United States District Court for the Central District of California sua sponte remands this employment action to the Superior Court of California, County of Orange. The court concludes that the state-law claims are not preempted under § 301 of the Labor Management Relations Act and that defendants failed to establish diversity jurisdiction because the amount in controversy was not shown to exceed $75,000. The court vacates all proceedings and removes the matter from its calendar.

Holdings

1. The plaintiff's state-law employment claims were not preempted under § 301 of the LMRA because they asserted rights arising from state law and could be resolved without interpreting the collective bargaining agreement.
2. Defendants failed to establish that the amount in controversy exceeded $75,000, so diversity jurisdiction was absent.
3. When the district court lacks subject-matter jurisdiction, it must remand a removed action to state court, including when the jurisdictional defect is identified sua sponte.

Questions Presented

1. Whether the plaintiff's state-law employment claims were completely preempted under § 301 of the Labor Management Relations Act because their resolution allegedly required interpretation of a collective bargaining agreement.
2. Whether federal diversity jurisdiction existed when Defendants failed to show by a preponderance of the evidence that the amount in controversy exceeded $75,000.
3. Whether the district court was required to remand the action sua sponte for lack of subject-matter jurisdiction.

Disposition

remanded