Vongdara v. Tech Digital Corporation

Summary

The United States District Court for the Southern District of California denied Delee Vongdara’s motion to remand a California wage-and-hour class action to state court. The court held that the defendants established federal subject-matter jurisdiction under the Class Action Fairness Act, including an amount in controversy exceeding $5 million. The court also denied plaintiff’s request for attorney’s fees and costs under 28 U.S.C. § 1447(c).

Holdings

1. The action satisfied CAFA's jurisdictional requirements because defendants demonstrated by a preponderance of the evidence that more than $5 million was in controversy.
2. Defendants could rely on the declaration of an individual who reviewed relevant employee payroll and wage data, and the assumed violation rates were reasonable in light of the complaint's allegations.
3. Plaintiff was not entitled to attorney's fees and costs under 28 U.S.C. § 1447(c) because defendants had an objectively reasonable basis for removal.

Questions Presented

1. Whether the proposed class action satisfied CAFA's subject matter jurisdiction requirements, including the amount-in-controversy threshold exceeding $5 million.
2. Whether defendants could rely on a declaration based on personnel and payroll data, together with reasonable assumptions drawn from the complaint, to establish the amount in controversy.
3. Whether plaintiff was entitled to attorney's fees and costs under 28 U.S.C. § 1447(c).

Disposition

other