Riley v. Amazon.com Services LLC

Background

Michael Riley filed a state-court complaint alleging product liability and negligence. The complaint sought damages for past and future medical expenses, wage loss, lost earning capacity, household services, incidental expenses, and pain and suffering. Amazon.com Services LLC removed the case to the U.S. District Court for the Northern District of California based on diversity jurisdiction, which generally requires citizens of different states and an amount in controversy exceeding $75,000.

Riley moved to remand, meaning he asked the federal court to return the case to state court. Amazon opposed the motion.

Procedural Defect Argument

Riley argued that remand was required because Amazon’s notice of removal incorrectly stated that he sought punitive damages and relied on legal authorities from the Central District of California and the Court of Appeals for the Fifth Circuit. The court rejected these arguments. Even assuming the punitive-damages statement was incorrect, Riley did not provide authority showing that the mistake justified remand. The court also held that citing persuasive cases from other courts was not a defect requiring remand.

Amount in Controversy

The court held that Amazon had the burden to prove, by a preponderance of the evidence, that the amount in controversy was more likely than not to exceed $75,000. The court rejected Amazon’s argument that merely listing multiple categories of damages established that threshold. The complaint only alleged that Riley was seriously injured, unlike cases Amazon cited involving more specific allegations of severe and permanent injuries or other substantial medical consequences.

The court also rejected Amazon’s reliance on Riley’s counsel’s description of the injuries as “life-altering,” references to deep lacerations and significant medical treatment in a pre-suit letter, and images included with that letter. The court noted that the record included a $12,201.53 hospitalization bill and showed that Riley was admitted to and discharged from the hospital on the same day. The court concluded that the evidence did not show that the amount in controversy was more likely than not to exceed $75,000.

The court further held that Riley’s alleged response to Amazon’s proposed stipulation to cap damages at $75,000 would not conclusively establish that the amount in controversy exceeded $75,000. The court noted that Riley disputed refusing to sign the stipulation.

Amazon separately objected to Riley’s submission of the medical bill as untimely. The court treated the objection as withdrawn after Amazon did not file the permitted sur-reply and stated that the objection was moot in any event.

Disposition

The court granted Riley’s motion to remand and remanded the case to Santa Clara County Superior Court. The court also vacated the hearing that had been set for January 29, 2026.