Sandoval v. Beacon Roofing Supply, Inc.

Background

Priscilla Sandoval sued Beacon Roofing Supply, Inc. and Joseph Junsay in Alameda County Superior Court. Beacon removed the case to the U.S. District Court for the Northern District of California. Sandoval moved to remand, meaning she asked the federal court to return the case to state court.

Jurisdiction

The court held that it lacked subject-matter jurisdiction—the legal authority to hear the case—over Sandoval’s state-law claims. Beacon relied on diversity jurisdiction under 28 U.S.C. § 1332(a), which requires every plaintiff to be a citizen of a different state from every defendant. Based on the complaint, Sandoval and Junsay were both citizens of California, so complete diversity was absent.

Beacon argued that Junsay had been fraudulently joined. Fraudulent joinder is a claim that a nondiverse defendant was included only to defeat federal jurisdiction, or that the plaintiff cannot establish a claim against that defendant in state court. The court explained that Beacon had a heavy burden and had not met it. Although Beacon argued that Sandoval had not pleaded enough facts for harassment or intentional infliction of emotional distress claims against Junsay, Beacon did not show that Sandoval could not add supporting facts by amending her complaint in state court.

Ruling

The court granted Sandoval’s motion to remand to Alameda County Superior Court. It terminated the pending motion to dismiss as moot and vacated the scheduled December 20, 2022 hearing. The order disposed of docket entries 5 and 10.