Rajapakse v. Freelancer

Background

Samantha Delane Rajapakse, proceeding without a lawyer, sued a company called Freelancer after a dispute involving her purchase of a vehicle through eBay Motors and the use of Escrow.com. She alleged that the vehicle was defective and that Escrow.com did not properly handle the transaction. She sought relief under several state-law theories, including breach of fiduciary duty, emotional distress, and loss of wages. She requested, among other things, the return of $1,965, $75,000 in punitive damages, and penalties for alleged California escrow-law violations.

Rajapakse named “Freelancer, a foreign Company d/b/a Escrow.com” as the defendant. Freelancer USA, Inc. was the only party served and argued that Rajapakse had sued the wrong party and had not alleged enough damages for federal diversity jurisdiction. The court had previously dismissed an earlier complaint for lack of subject-matter jurisdiction and allowed Rajapakse to amend.

Jurisdictional amount

The court explained that diversity jurisdiction requires diverse citizenship and an amount in controversy exceeding $75,000. Construing Rajapakse’s allegations liberally, the court estimated approximately $25,000 in vehicle-storage costs, $35,500 in rideshare expenses, and $1,965 related to the vehicle transaction, for a total of $62,465. The court concluded that this amount did not satisfy the jurisdictional requirement.

The court also addressed Rajapakse’s request for $75,000 in punitive damages. It stated that she had not shown the required fiduciary relationship under California or Tennessee law. The court further stated that her allegations continued to sound in contract, for which punitive damages are not available under the California breach-of-contract law discussed in the opinion. The court granted the motion to dismiss on the jurisdictional amount without needing to resolve those issues.

Correct party

Because it dismissed the Second Amended Complaint for lack of subject-matter jurisdiction, the court declined to decide Freelancer USA’s argument that Rajapakse had sued the wrong party. The court stated that the relationship among Escrow.com, Internet Escrow Services, and the Freelancer entities was an issue Rajapakse would have to resolve if she pursued the matter in state court.

Disposition

The court granted Freelancer USA’s second motion to dismiss. It dismissed Rajapakse’s Second Amended Complaint with prejudice because she had made three attempts to bring the case in the Northern District of California and still could not meet the jurisdictional requirements. The court also dismissed Rajapakse’s motion for summary judgment as moot, vacated the scheduled case-management conference and related deadlines, ordered judgment entered, and directed the Clerk to close the file. The court stated that Rajapakse might still have a legal claim suited for state court.