Rosales v. Vitas Healthcare Corporation of California

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, relying on diversity jurisdiction. Vitas asserted that it was incorporated in Delaware and headquartered in Florida.

Jurisdictional issue

Federal diversity jurisdiction requires complete diversity of citizenship between the parties and an amount in controversy greater than $75,000. The party removing a case bears the burden of showing that removal is proper, and the federal court must independently confirm that it has subject-matter jurisdiction.

Vitas submitted a declaration from Dean Robertson, identified as in-house counsel and a vice-president for Vitas’s parent corporation. The declaration stated, without further explanation, that Vitas’s headquarters was in Miami, Florida. Applying the rule that a corporation’s principal place of business is ordinarily its headquarters when that location is the actual center of the company’s direction, control, and coordination, the court found the conclusory statement insufficient to establish that Vitas’s principal place of business was Florida.

The court also noted errors in a declaration referred to in the opinion, including statements that Rosales filed the lawsuit in Riverside County and that the summons was served on the registered agent for O’Reilly Auto Enterprises, LLC.

Order

The court ordered Vitas to show cause—provide an explanation—on or before July 28, 2024, why the action should not be remanded to state court for lack of subject-matter jurisdiction. Rosales could respond by August 11, 2025, after which the court stated it would take the issue under submission. The opinion does not state a final decision on remand.