Sylvia Williams v. Costco Wholesale Corporation

Summary

The United States District Court for the Central District of California remanded Sylvia Williams’s state-law negligence and premises-liability action against Costco Wholesale Corporation for lack of subject matter jurisdiction. The court held that Costco failed to prove by a preponderance of the evidence that the amount in controversy exceeded $75,000 for diversity jurisdiction. The court denied Williams’s request for attorney’s fees and costs because Costco had an objectively reasonable basis for removal.

Holdings

1. Costco failed to prove by a preponderance of the evidence that the amount in controversy exceeded $75,000; therefore, the court lacked diversity subject matter jurisdiction and was required to remand the action.
2. Williams was not entitled to attorney's fees and costs under 28 U.S.C. § 1447(c) because Costco had an objectively reasonable basis for removal, notwithstanding the court's conclusion that jurisdiction was lacking.

Questions Presented

1. Whether Costco established by a preponderance of the evidence that the amount in controversy exceeded $75,000 so that diversity jurisdiction existed.
2. Whether Williams was entitled to attorney's fees and costs under 28 U.S.C. § 1447(c) after remand.

Disposition

remanded