Artrelle Fowler v. DoorDash Essentials, LLC d/b/a DoorDash, et al.

Summary

The United States District Court for the Eastern District of Missouri denied Artrelle Fowler’s motion to remand an employment-discrimination action removed from Missouri state court. The court held that defendants established by a preponderance of the evidence that the amount in controversy exceeded $75,000 and found that the nondiverse defendant was fraudulently joined because the Missouri Human Rights Act preempted the common-law emotional-distress claim. The case therefore remained in federal court under diversity jurisdiction.

Holdings

1. Defendants established by a preponderance of the evidence that the amount in controversy exceeded $75,000.
2. Wright was fraudulently joined because Fowler's common-law emotional-distress claim against him was based on the same conduct underlying Fowler's MHRA claims, and the MHRA provided the exclusive remedy for that conduct.
3. Remand was unwarranted because federal subject matter jurisdiction existed under 28 U.S.C. § 1332 after disregarding the fraudulently joined defendant.

Questions Presented

1. Whether the amount in controversy exceeded $75,000 for purposes of diversity jurisdiction.
2. Whether the presence of Wright defeated complete diversity because Fowler alleged that Wright was a Missouri citizen.
3. Whether Wright was fraudulently joined because the Missouri Human Rights Act preempted Fowler's common-law emotional-distress claim based on the same conduct.
4. Whether the action should be remanded to state court for lack of subject matter jurisdiction.

Disposition

remanded