Maria Lopez v. Target Corporation

Summary

The United States District Court for the Northern District of California granted Maria Lopez leave to amend her slip-and-fall complaint to add Target employees Raul Medina and Lotty Rocha as defendants. Because the proposed defendants were nondiverse California residents, the court deferred ruling on remand and stated that it would address that request in a separate order or report and recommendation.

Holdings

1. Under 28 U.S.C. § 1447(e), a district court has discretion either to deny joinder of nondiverse defendants or to permit joinder and remand the action, and the relevant factors favored permitting Lopez to amend her complaint to add Medina and Rocha.
2. For purposes of joinder under § 1447(e), Lopez's negligence and premises-liability claims against Medina and Rocha appeared valid; the allegations therefore did not establish that joinder was sought solely to defeat diversity jurisdiction.

Questions Presented

1. Whether the court should permit Lopez to amend her complaint under 28 U.S.C. § 1447(e) to add nondiverse defendants whose joinder would destroy diversity jurisdiction.
2. Whether the proposed negligence and premises-liability claims against Medina and Rocha appeared valid and were asserted for purposes other than solely defeating federal jurisdiction.

Disposition

other