Chapdelaine v. Gold Club-SF, LLC
- Thomas Hixson
- 3:24-cv-04304
- U.S. District Court · Northern District of California
- 3
In Chapdelaine v. Gold Club-SF, LLC, Judge Hixson ordered Jessica Chapdelaine to explain why her employment case should not be dismissed for lack of federal jurisdiction.
Jessica Chapdelaine and the defendant entities named in the action. The order requires Chapdelaine to address the court’s jurisdiction concern and could lead to dismissal if she does not respond.
What happened
In Chapdelaine v. Gold Club-SF, LLC, Jessica Chapdelaine sued Gold Club-SF, LLC, SFBSC Management, LLC, S.A.W. Entertainment Limited, Garden of Eden, LLC, Bijou-Century, LLC, and Déjà Vu–San Francisco, LLC. She asserted California employment-law claims involving wages, breaks, expenses, tips, wage statements, harassment, retaliation, and civil penalties.
Chapdelaine said federal jurisdiction existed because she was a California citizen and the defendants were Nevada business entities. But the court noted that S.A.W. Entertainment Limited was incorporated in California, which appeared to defeat the requirement that opposing parties be citizens of different states. The court also said the claims appeared to arise entirely under state law.
Judge Thomas S. Hixson ordered Chapdelaine to file a written response by September 19, 2024, explaining why the case should not be dismissed for lack of subject-matter jurisdiction. The court said failure to respond would result in dismissal, allowed responses and a reply on the jurisdiction issue, and vacated the September 26 hearing on the defendants’ motion to dismiss.
The detailed version
- Chapdelaine v. Gold Club-SF, LLC · No. 3:24-cv-04304
- Thomas Hixson
- Sept. 12, 2024
Background
On July 17, 2024, Jessica Chapdelaine sued Gold Club-SF, LLC; SFBSC Management, LLC; S.A.W. Entertainment Limited; Garden of Eden, LLC; Bijou-Century, LLC; and Déjà Vu–San Francisco, LLC. Her complaint asserted 14 claims under California law, including claims concerning rest and meal periods, minimum and overtime wages, business-expense reimbursement, payment of wages, tips, wage statements, sexual harassment, failure to prevent harassment, retaliation, and civil penalties under California’s Private Attorneys General Act.
Jurisdiction concern
The court explained that federal courts have limited authority and must independently determine whether they have subject-matter jurisdiction, meaning legal authority to hear the case. The complaint relied on diversity jurisdiction under 28 U.S.C. § 1332, alleging that Chapdelaine was a California citizen and that the defendants were Nevada business entities. Diversity jurisdiction generally requires the amount in controversy to exceed $75,000 and complete diversity between opposing parties.
The court noted that S.A.W. Entertainment Limited was identified in the complaint and a filing with the California Secretary of State as a California corporation. A corporation is treated as a citizen of its state of incorporation, so complete diversity did not appear to exist. The court also noted that federal-question jurisdiction did not appear to exist because all of the claims arose under state law. The opinion mentioned a separate exception for certain class actions but did not treat that exception as establishing jurisdiction here.
Order
The court ordered Chapdelaine to show cause—in other words, to explain in writing—why the case should not be dismissed for lack of subject-matter jurisdiction. Her response was due September 19, 2024. The court stated that failure to respond would result in dismissal of the action for lack of jurisdiction. The defendants could respond by September 26, 2024, and Chapdelaine could reply by October 3, 2024. The court also vacated the September 26 hearing on the defendants’ motion to dismiss. The court did not decide the underlying employment claims in this order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.