Le Geng Lin v. Amazon.com, Inc., et al.

Summary

The United States District Court for the Central District of California grants Plaintiff Le Geng Lin’s motion to remand a product-liability action against Amazon defendants. The court finds complete diversity but concludes that Defendants failed to establish by a preponderance of the evidence that the amount in controversy exceeds $75,000. The court denies Plaintiff’s motion for sanctions and costs under 28 U.S.C. § 1447(c), remands the action to Los Angeles County Superior Court, and closes the federal case.

Holdings

1. Defendants established complete diversity because Plaintiff was a California citizen, Amazon.com, Inc. was a citizen of Delaware and Washington, and Amazon.com Services, LLC was a citizen of the states of its members, including Delaware and Washington, rather than California.
2. Remand was required because Defendants failed to establish by a preponderance of the evidence that the amount in controversy exceeded $75,000.
3. Plaintiff was not entitled to sanctions, costs, or attorney's fees under 28 U.S.C. § 1447(c) because Defendants had an objectively reasonable basis for removal, and Plaintiff proceeded pro se.

Questions Presented

1. Whether complete diversity existed between Plaintiff and Defendants for purposes of removal.
2. Whether Defendants established by a preponderance of the evidence that the amount in controversy exceeded $75,000 under 28 U.S.C. § 1332(a).
3. Whether Plaintiff was entitled to costs and attorney's fees under 28 U.S.C. § 1447(c) based on allegedly improper removal.

Disposition

remanded