Gastelum v. Starbucks
- Nathanael Cousins
- 5:22-cv-08149
- U.S. District Court · Northern District of California
- 2
In Gastelum v. Starbucks, Judge Cousins ordered Gastelum to explain whether his state-law claims meet diversity jurisdiction’s amount requirement before possible dismissal.
Fernando Gastelum and Starbucks Corporation; the order specifically concerns Gastelum’s state-law claims under the Unruh Civil Rights Act, the Disabled Persons Act, and for malice and oppression.
What happened
In Gastelum v. Starbucks, Fernando Gastelum brought state-law claims against Starbucks Corporation under the Unruh Civil Rights Act, the Disabled Persons Act, and for malice and oppression.
The court said Gastelum had not provided enough information to show that the amount in dispute exceeded $75,000, as required for diversity jurisdiction. The court ordered him to explain in writing by August 8, 2024, how the claims meet that requirement and why they should not be dismissed for lack of subject-matter jurisdiction.
Judge Nathanael M. Cousins issued an order to show cause; the opinion did not dismiss the claims in this order.
The detailed version
- Gastelum v. Starbucks · No. 5:22-cv-08149
- Nathanael Cousins
- July 25, 2024
Background
Fernando Gastelum asserted state-law claims against Starbucks Corporation under the Unruh Civil Rights Act, the Disabled Persons Act, and for malice and oppression. Gastelum claimed that the court had diversity jurisdiction. Diversity jurisdiction generally requires complete diversity of citizenship and an amount in controversy greater than $75,000.
Court’s Analysis
The court explained that federal courts have limited subject-matter jurisdiction, meaning they may hear only matters authorized by federal law. The court found that Gastelum had not provided enough information to determine whether the amount-in-controversy requirement for diversity jurisdiction was satisfied. Gastelum referred to the cost of complying with injunctive relief, statutory damages, and attorney’s fees, but the court stated that more information was needed.
Order
The court ordered Gastelum to show cause in writing by August 8, 2024, why his state-law claims should not be dismissed for lack of subject-matter jurisdiction. This order did not dismiss the claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.