Woodbury v. Federal Express Corporation
- Jacquelyn Corley
- 3:25-cv-06673
- U.S. District Court · Northern District of California
- 6
In Jason Woodbury v. Federal Express Corporation, Judge Corley remanded the employment case to state court and denied the individual defendants’ dismissal motion as moot.
Jason Woodbury’s case returns to California state court. Federal Express, John Wiens, and John Wagner must litigate there; the federal court did not decide the underlying employment claims.
What happened
Jason Woodbury sued Federal Express Corporation, John Wiens, and John Wagner in California state court, alleging employment discrimination and related claims. Federal Express transferred the case to federal court, arguing that Wiens and Wagner were improperly added to defeat federal jurisdiction.
The court found that Wiens and Wagner were California citizens like Woodbury and that Federal Express had not shown they were sham defendants. Because their presence prevented the required diversity of citizenship, the federal court concluded it lacked authority to hear the case. The court did not decide the parties’ other arguments about the emotional-distress claim or the amount in controversy.
Judge Corley granted Woodbury’s motion to send the case back to state court and denied Wiens and Wagner’s motion to dismiss as moot. The ruling resolved the federal court’s jurisdiction but did not decide the underlying employment claims.
The detailed version
- Woodbury v. Federal Express Corporation · No. 3:25-cv-06673
- Jacquelyn Corley
- Oct. 30, 2025
Background
Jason Woodbury sued Federal Express Corporation (FedEx), John Wiens, and John Wagner in Alameda County Superior Court. The complaint alleged employment discrimination and related claims under the California Fair Employment and Housing Act, including disability discrimination, retaliation, failure to accommodate, failure to engage in an interactive process, failure to prevent discrimination or retaliation, and disability harassment. It also alleged contract, negligent supervision, wrongful termination, whistleblower-retaliation, and intentional-infliction-of-emotional-distress claims.
Woodbury alleged that Wiens and Wagner were managers who assigned him additional work, responded negatively to his safety and injury complaints, reprimanded him, and took other actions he viewed as retaliatory. After a thumb injury, he was placed on light duty. He later was suspended and terminated by FedEx, which cited three disciplinary notices.
FedEx removed the case from state court based on diversity jurisdiction. It argued that Wiens and Wagner were sham defendants whose California citizenship should be disregarded. Woodbury moved to remand, meaning to return the case to state court. Wiens and Wagner separately moved to dismiss the claims against them.
Why the Court Remanded the Case
Diversity jurisdiction generally requires every plaintiff to be a citizen of a different state from every defendant, as well as an amount in controversy exceeding $75,000. Woodbury and the individual defendants were alleged to be California citizens. FedEx was alleged to be a citizen of Delaware and Tennessee, so Wiens and Wagner prevented complete diversity unless FedEx established fraudulent joinder.
Fraudulent joinder is a limited exception that allows a federal court to disregard a nondiverse defendant when the plaintiff either falsely pleaded jurisdictional facts or cannot possibly establish any cause of action against that defendant in state court. The defendant invoking this exception bears a heavy burden.
The court rejected FedEx’s argument that Woodbury’s harassment allegations merely failed to satisfy the ordinary standard for stating a claim under the federal dismissal rule. The court explained that the fraudulent-joinder inquiry asks whether Wiens and Wagner could be liable on any theory, not simply whether the complaint currently meets the dismissal standard. The court also noted that a claim could be viable if there were a possibility that a state court would find the allegations sufficient, including after an amendment.
The court concluded that Woodbury stated a possible California Fair Employment and Housing Act harassment claim against Wiens and Wagner based on their conduct following his thumb injury. The court therefore found that FedEx had not shown the individual defendants were sham defendants. Their presence destroyed complete diversity, leaving the federal court without subject-matter jurisdiction.
Rulings
The court granted Woodbury’s motion to remand. It denied Wiens and Wagner’s motion to dismiss as moot. The court did not decide FedEx’s arguments concerning the intentional-infliction-of-emotional-distress claim or whether the amount in controversy exceeded $75,000, because the lack of complete diversity already required remand. The court also vacated the scheduled November 6, 2025 hearing.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.