Amezcua v. CRST Expedited, Inc.
- Yvonne Rogers
- 4:22-cv-06501
- U.S. District Court · Northern District of California
- 2
In Amezcua v. CRST Expedited, Inc., Judge Rogers ordered briefing on possible class-action jurisdiction exceptions but did not decide remand.
Ricardo Amezcua, CRST Expedited Inc., Gamino & Associates, Inc., and the proposed class of employees described in the complaint were affected by the court’s request for supplemental jurisdictional briefing.
What happened
In Amezcua v. CRST Expedited, Inc., Ricardo Amezcua asked the court to send his case back from federal court. His complaint alleges that he is a California citizen and seeks to represent employees of the defendants who worked in California and suffered injuries during that employment.
The court said the Class Action Fairness Act may allow federal jurisdiction over the class action, but it also identified possible exceptions for cases involving mainly local parties and injuries. Because at least one defendant appeared to be a California citizen, the court ordered more information before deciding the remand request.
Judge Yvonne Rogers ordered Amezcua to respond by January 10, 2023, and allowed the defendants to file an optional response by January 17, 2023. The court vacated the January 10 hearing and did not decide the motion to remand.
The detailed version
- Amezcua v. CRST Expedited, Inc. · No. 4:22-cv-06501
- Yvonne Rogers
- Jan. 5, 2023
Background
Ricardo Amezcua filed a class action against CRST Expedited Inc. and Gamino & Associates, Inc. He moved to remand, meaning he asked the federal court to return the case to the court from which it was removed. The opinion does not state the court from which the case was removed.
The complaint alleges that Amezcua is a California citizen and seeks to represent a class of the defendants’ employees who worked in California and sustained injuries during that employment. The court stated that at least one defendant appeared to be a California citizen.
Jurisdictional Issues
The Class Action Fairness Act, or CAFA, generally gives federal courts original jurisdiction over class actions when the total amount in controversy exceeds $5 million, at least one class member is a citizen of a different state than a defendant, and the proposed class has at least 100 members.
The court explained that CAFA contains exceptions requiring a federal court to decline jurisdiction in certain predominantly local cases. The local controversy exception can apply when more than two-thirds of the proposed class members are citizens of the state where the action was filed, the principal injuries occurred there, and at least one significant defendant is a citizen of that state. The mandatory home state exception can apply when at least two-thirds of the proposed class members and the primary defendants are citizens of the filing state.
Based on the complaint’s allegations, the court was concerned that one or both exceptions might bar CAFA jurisdiction. The opinion does not decide whether either exception applies.
Order
The court ordered Amezcua to file a written response addressing whether one of the exceptions applies by January 10, 2023. It stated that failure to respond would be treated as a concession that the exceptions do not apply. The defendants could file an optional response by January 17, 2023. Judge Yvonne Rogers vacated the hearing scheduled for January 10 and stated that it would be reset if necessary. The court did not rule on the motion to remand or otherwise decide the merits of the case.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.