Knuth v. Amazon.com Services LLC

Background

Aaron Knuth filed this action against his former employer, Amazon.com Services LLC, in the Superior Court of California for San Francisco County. Amazon removed the case to federal court based on diversity jurisdiction. Diversity jurisdiction generally allows a federal court to hear a case involving citizens of different states when the amount in controversy exceeds $75,000.

Knuth’s original and amended complaints stated that he was an individual with his residence in California. Amazon’s principal place of business was stated to be in Washington. The parties later disputed whether Knuth’s California residence established California citizenship. Citizenship for diversity purposes is based on domicile—the person’s permanent home and intent to remain there—not merely residence.

Knuth repeatedly raised the jurisdiction issue during case-management proceedings. He argued that he currently lived in Washington and intended to remain there. He relied on a statement by Amazon that he was a Washington resident at all relevant times. Amazon explained that statement concerned choice of law and did not address Knuth’s citizenship when the case was filed and removed.

Motion to Remand

Knuth moved to remand, asking the federal court to return the case to state court. He submitted no evidence, sworn statement, or other declaration about his residence, domicile, or citizenship when he filed the case or when Amazon removed it. He also had not amended his complaint to correct or explain its statements that he was a California resident.

Amazon did not dispute that Knuth’s current residential address was in Washington. Amazon also stated that Knuth had been employed out of a facility in Washington. But Amazon argued that diversity must exist when the complaint is filed and the case is removed, and that Knuth had not provided information about his citizenship at that time.

Court’s Analysis

The court stated that Amazon, as the party relying on federal jurisdiction, had to prove by a preponderance of the evidence that removal was proper. The court also stated that diversity is determined when the complaint is filed and removal occurs; a later change in citizenship does not destroy jurisdiction once it attaches.

On the limited record, the court found that Amazon met its burden. The court relied on Knuth’s statements in both complaints that he was a California resident, together with his failure to provide evidence or amend the operative complaint to clarify his citizenship at the relevant time. The court acknowledged that the record was limited because Knuth had not provided evidence about his citizenship.

Disposition

Judge William H. Orrick denied the motion to remand. The opinion did not decide the underlying employment claims. The court also warned that similar conduct in the future could result in sanctions.