Nik Venet v. Recreational Equipment, Inc.

Summary

The United States District Court for the Central District of California denied Plaintiff Nik Venet’s motion to remand a putative California wage-and-hour class action removed under the Class Action Fairness Act. The court held that minimal diversity and numerosity were undisputed and that Defendant established by a preponderance of the evidence that the amount in controversy exceeded $5 million. Plaintiff’s request to appear remotely was deemed moot.

Holdings

1. The amount in controversy exceeded $5 million, satisfying CAFA's jurisdictional threshold.
2. Defendant's assumptions were sufficiently grounded in the complaint and underlying employment data to establish the amount in controversy, although a 100% violation rate was unwarranted for waiting-time and wage-statement penalties.

Questions Presented

1. Whether the federal court had CAFA jurisdiction because the amount in controversy exceeded $5 million.
2. Whether Defendant's evidence and assumptions regarding potential damages were sufficient to establish the amount in controversy by a preponderance of the evidence.
3. Whether the motion to remand should be granted.

Disposition

other