Arakji v. Microchip Technology, Inc.

Background

Mazen Arakji, representing himself, brought the action against Microchip Technology, Inc. in the Superior Court of California for Santa Clara County. He alleged violations of the California Fair Employment and Housing Act. Microchip removed the action to the U.S. District Court for the Northern District of California based on diversity jurisdiction, which allows a federal court to hear certain disputes involving citizens of different states when the amount in controversy meets the statutory requirement.

Arakji moved to remand, or return, the case to state court. The court denied that motion. According to the earlier order, Arakji did not dispute that the parties were diverse, so the remaining issue was the amount in controversy. The court concluded that the claimed $74,000 in damages for pain, suffering, and inconvenience, combined with the value of the requested employment-related injunctive relief, exceeded the jurisdictional amount.

Request for Reconsideration

Arakji filed objections to the remand order. The court construed the filing as a motion for leave under Civil Local Rule 7-9 to file a motion for reconsideration of an interlocutory order.

That rule required Arakji to show reasonable diligence and one of three circumstances: a material difference in fact or law that was previously unknown despite diligence; new material facts or a change in law after the order; or a manifest failure by the court to consider material facts or dispositive legal arguments previously presented.

Arakji raised three points. He argued that the court had mischaracterized a factual allegation about his on-site interview; that his statement of damages was modified before removal rather than afterward; and that the court incorrectly valued the requested injunctive relief because he sought an employment offer, not actual employment for a period of time.

Court’s Analysis

The court held that Arakji did not satisfy Civil Local Rule 7-9(b). It found that he had not identified a material difference in fact or law, new material facts or a change in law, or a manifest failure to consider previously presented material facts or legal arguments.

The court described the filing as an impermissible attempt to relitigate the remand motion. It concluded that the disagreement about the interview did not affect the value of the claims for diversity-jurisdiction purposes. It also noted that the earlier remand order had specifically stated that the court did not base its decision on the post-removal status of the statement of damages. Finally, the court rejected Arakji’s distinction between seeking an employment offer and seeking employment, describing that distinction as an attempt to manipulate jurisdiction.

Disposition

The court denied Arakji’s motion for reconsideration. The opinion does not decide the underlying Fair Employment and Housing Act claims.