Saranay Sonny Ballungay v. Ricoh USA, Inc.

Summary

The United States District Court for the Central District of California denied Plaintiff Saranay Sonny Ballungay’s motion to remand a putative wage-and-hour class action against Ricoh USA, Inc. The court held that CAFA minimal diversity was satisfied and that Defendant demonstrated by a preponderance of the evidence that the amount in controversy exceeded $5 million. The court relied on allegations concerning unpaid travel time and unreimbursed mileage, together with evidence regarding the proposed class size and workweeks.

Holdings

1. CAFA's minimal-diversity requirement was satisfied because Plaintiff was a California citizen and Ricoh was a citizen of Delaware, where it was incorporated, and Pennsylvania, where its principal place of business was located.
2. Defendant established by a preponderance of the evidence that the amount in controversy exceeded $5 million.
3. Ricoh's assumptions that each class member worked one hour of unpaid overtime per week and incurred 150 unreimbursed miles per week were reasonable because they were sufficiently tethered to the complaint's systemic allegations.

Questions Presented

1. Whether CAFA's minimal-diversity requirement was satisfied.
2. Whether Defendant established by a preponderance of the evidence that the aggregate amount in controversy exceeded CAFA's $5 million threshold.
3. Whether the assumptions underlying Defendant's wage and mileage calculations were sufficiently tethered to the allegations of the complaint to establish the amount in controversy.

Disposition

other