Rosales v. Vitas Healthcare Corporation of California
- Jacquelyn Corley
- 3:25-cv-05417
- U.S. District Court · Northern District of California
- 2
Counsel of record per CourtListener. Firm names are approximate.
In Rosales v. Vitas Healthcare, Judge Corley ordered Vitas to explain why the case should not return to state court for lack of jurisdiction.
Vitas Healthcare Corporation of California must address whether federal diversity jurisdiction exists; Zoila Rosales may respond. The court’s jurisdictional review could determine whether the case remains in federal court or returns to state court.
What happened
In Rosales v. Vitas Healthcare Corporation of California, Zoila Rosales brought a state-law case in state court, and Vitas Healthcare Corporation of California moved it to federal court based on diversity jurisdiction.
Vitas said it was incorporated in Delaware and headquartered in Florida. The court explained that federal diversity jurisdiction requires complete diversity between the parties and more than $75,000 at stake, and that Vitas had to prove those requirements.
Judge Jacquelyn Corley found that a declaration merely stating that Vitas was headquartered in Miami was not enough to establish the company’s principal place of business. She ordered Vitas to show cause—explain—why the case should not be sent back to state court, and allowed Rosales to respond.
The detailed version
- Rosales v. Vitas Healthcare Corporation of California · No. 3:25-cv-05417
- Jacquelyn Corley
- July 15, 2025
Background
Zoila Rosales filed a state-law action in state court. Vitas Healthcare Corporation of California removed the action to the U.S. District Court for the Northern District of California, asserting diversity jurisdiction. Vitas represented that it was incorporated in Delaware and headquartered in Florida.
Jurisdictional standard
Federal diversity jurisdiction requires complete diversity of citizenship and an amount in controversy exceeding $75,000. The party seeking removal must establish that removal is proper. The federal court also has an independent duty to determine whether it has subject-matter jurisdiction, meaning authority to decide the case. If that jurisdiction is lacking before final judgment, the case must be returned to state court.
For a corporation, the court explained, the principal place of business is ordinarily its headquarters if that location is the company’s actual center of direction, control, and coordination—not merely an office used for board meetings.
Court’s analysis
Vitas supported removal with a declaration from Dean Robertson, described as an in-house counsel and vice-president for Vitas’s parent corporation. The declaration stated, without further explanation, that Vitas’s headquarters was in Miami, Florida. Judge Jacquelyn Scott Corley held that this conclusory statement was insufficient to establish Vitas’s principal place of business in Florida for diversity-jurisdiction purposes.
The court also noted that a declaration by Paradis incorrectly stated that Rosales filed her lawsuit in Riverside County and that service was made on the registered agent for O’Reilly Auto Enterprises, LLC.
Order
The court ordered Vitas to show cause—provide an explanation—why the action should not be remanded to state court for lack of subject-matter jurisdiction. The opinion states that Vitas’s response was due on July 28, 2024, and that Rosales could respond by August 10, 2025. The court stated that it would take the issue under submission at that time. The opinion does not order a remand or otherwise finally resolve the case.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.