Bland v. Marin Airporter

Background

Maggie Bland filed this action in Marin County Superior Court on December 14, 2020. Marin Airporter removed the case to federal court on March 10, 2021. The opinion states that Marin Airporter’s removal was based on hours-of-service regulations issued by the Federal Motor Carrier Safety Administration.

Motions

Marin Airporter moved to dismiss Bland’s claim under California’s Private Attorneys General Act and to strike the related allegations. Bland moved to remand, meaning to return the case to state court, arguing that the federal court lacked subject-matter jurisdiction—the authority to hear the case.

Court’s reasoning

The court stated that subject-matter jurisdiction depends only on the named plaintiffs. Bland was a cashier, and the court concluded that the federal hours-of-service regulations used as the basis for removal did not cover her claims. The court said that this alone made remand appropriate. It also noted that, even if Bland were a driver, it was not clear how Marin Airporter could show that the drivers were engaged in interstate commerce, given the local nature of the work described in the opinion.

Ruling

Judge Yvonne Gonzalez Rogers granted Bland’s motion to remand the case to state court. The court denied as moot Marin Airporter’s motion to dismiss and strike. The clerk was directed to remand the case to Marin County Superior Court and close the federal file.