Semler Scientific v. Joshua Robert Daniels

Background

Joshua Robert Daniels removed Semler Scientific, Inc.’s case from Santa Clara County Superior Court to the U.S. District Court for the Northern District of California. The court issued an order to show cause, meaning it required Daniels to explain why the case should not be sent back to state court. The order concerns whether the federal court has subject-matter jurisdiction, or legal authority to hear the case.

Jurisdictional Issues

The court explained that federal district courts generally obtain subject-matter jurisdiction through federal-question jurisdiction or diversity jurisdiction. Daniels relied on diversity jurisdiction. Diversity jurisdiction requires complete diversity of citizenship and an amount in controversy greater than $75,000.

The court found that Daniels had not sufficiently established complete diversity. His filing described Semler Scientific as a Delaware corporation with its principal place of business in California and described himself as a resident of the United Kingdom. The court explained that the statute concerns citizenship, not residence, and that an individual’s citizenship depends on domicile. Because Daniels did not allege where he was domiciled, the court could not determine whether complete diversity existed.

The court also found that Daniels did not meet his burden of establishing an amount in controversy exceeding $75,000. Because Semler Scientific seeks nonmonetary declaratory relief concerning the fee it may owe Daniels for his counsel’s work, the relevant amount is the value of that requested relief. The court concluded that the complaint did not suggest that the fee’s value exceeded $75,000 and that Daniels’s argument about work related to Semler Scientific’s bylaws was speculative.

Ruling and Next Steps

Judge Nathanael M. Cousins ordered Daniels to show cause in writing by November 10, 2025, why the case should not be remanded to state court for lack of subject-matter jurisdiction. Semler Scientific may respond by November 17, 2025. The opinion does not state that the court actually remanded the case or finally resolved the jurisdiction issue.