Floyd v. Saber Fitness Hegenberger, LLC
- Thomas Hixson
- 3:24-cv-01278
- U.S. District Court · Northern District of California
- 3
In Floyd v. Saber Fitness Hegenberger, LLC, Judge Hixson ordered responses explaining why the case should not be sent back for lack of jurisdiction.
Michael Devin Floyd and Saber Fitness Hegenberger, LLC; the order required either or both parties to address whether the case should be remanded to state court.
What happened
In Floyd v. Saber Fitness Hegenberger, LLC, Michael Devin Floyd originally sued in state court and later added federal claims before the defendant moved the case to federal court.
Floyd’s second amended complaint removed the federal claims and asserted only state-law claims. The court noted that both parties appeared to be in California, so neither federal-question jurisdiction nor diversity jurisdiction appeared to exist.
Judge Thomas S. Hixson ordered one or both parties to explain why the case should not be sent back to state court for lack of jurisdiction. The order did not finally decide whether remand would occur.
The detailed version
- Floyd v. Saber Fitness Hegenberger, LLC · No. 3:24-cv-01278
- Thomas Hixson
- July 15, 2024
Background
Michael Devin Floyd initially filed this case in Alameda Superior Court on July 3, 2023, naming “Planet Fitness of Oakland, CA” as the defendant. On January 30, 2024, he filed a first amended complaint naming Saber Fitness Hegenberger, LLC and asserting ten claims, including claims under federal civil-rights statutes and several California laws. Saber later moved the case to federal court based on federal-question jurisdiction and moved to dismiss the complaint.
On July 11, 2024, Floyd filed a second amended complaint asserting only state-law claims. The opinion does not describe a ruling on Saber’s earlier motion to dismiss.
Jurisdiction analysis
The court explained that federal courts may hear cases based on federal-question jurisdiction or diversity jurisdiction. Federal-question jurisdiction generally covers claims arising under federal law. Diversity jurisdiction generally requires more than $75,000 in dispute and parties who are citizens of different states, or a citizen of a state and a citizen of another country.
Because Floyd’s second amended complaint asserted only state-law claims, the court concluded that federal-question jurisdiction was lacking. The court also stated that both parties were in California, so diversity jurisdiction appeared to be lacking as well. The court further noted that it could decline to hear the remaining state-law claims through supplemental jurisdiction if all claims within the court’s original authority had been dismissed, and that the case was still at the pleading stage.
Order
The court ordered either or both parties to show why the case should not be remanded for lack of jurisdiction. The excerpt provided does not include the deadline for the written responses and does not show a final ruling on remand. Judge Thomas S. Hixson signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.