Rebecca Castillo v. Tommy Bahama R&R Holdings, Inc. et al.

Summary

The United States District Court for the Central District of California grants Rebecca Castillo’s motion to remand an action against Tommy Bahama R&R Holdings, Inc. concerning alleged website accessibility barriers. The court holds that Castillo’s amended Unruh Civil Rights Act claim includes an independent state-law theory and therefore does not necessarily present a federal question, and that the defendant failed to establish the amount-in-controversy requirement for diversity jurisdiction. The court remands the action to Los Angeles County Superior Court and denies Castillo’s request for removal-related attorneys’ fees.

Holdings

1. Federal-question jurisdiction did not attach because Castillo plausibly pleaded an alternative, independent state-law theory of liability under the Unruh Civil Rights Act based on intentional discrimination; therefore, federal law was not a necessary element of the claim.
2. Tommy Bahama failed to prove by a preponderance of the evidence that the amount in controversy exceeded $75,000. The court calculated $12,000 in statutory damages, credited Castillo's $50,000 limitation on injunctive-relief costs, and included $1,500 in attorney fees, for a total of $63,500.
3. Castillo was not entitled to attorney fees under 28 U.S.C. § 1447(c) because Tommy Bahama had an objectively reasonable basis for removal in light of ambiguity concerning federal jurisdiction over Unruh claims seeking injunctive relief.

Questions Presented

1. Whether the First Amended Complaint's Unruh Civil Rights Act claim presented a federal question because it referenced or was partly premised on ADA violations.
2. Whether Tommy Bahama established diversity jurisdiction by proving that the amount in controversy exceeded $75,000, including statutory damages, injunctive relief, and attorney fees.
3. Whether Castillo was entitled to attorney fees incurred because of the removal under 28 U.S.C. § 1447(c).

Disposition

remanded