Cao v. Autel US Inc.
- 3:22-cv-05301
- U.S. District Court · Northern District of California
- 4
In Cao v. Autel US Inc., the court remanded the case to state court because Autel did not prove federal jurisdiction; the judge is unnamed.
Yongyan Cao and Autel US Inc.; the case returned to state court, and the federal court did not decide the underlying claims.
What happened
Cao v. Autel US Inc. began in California state court, where Yongyan Cao brought claims involving an unpaid bonus, labor-code violations, and California’s unfair-competition law. Autel removed the case to federal court, claiming the parties were diverse and more than $75,000 was at stake.
The federal court found that Autel had not proved the required amount in controversy. The court estimated the maximum at $73,173, below the jurisdictional threshold, and found Autel’s unsupported assertions and missing calculations insufficient.
The court remanded the case to state court for lack of subject-matter jurisdiction. The opinion does not identify the judge by name.
The detailed version
- Cao v. Autel US Inc. · No. 3:22-cv-05301
- Aug. 31, 2023
Background
Yongyan Cao filed a state-court complaint against Autel US Inc. asserting state-law claims related to breach of contract, labor-code violations, and California’s Unfair Competition Law. The complaint did not specify the amount of damages sought.
Autel removed the case to federal court based on diversity jurisdiction. Diversity jurisdiction generally requires complete diversity between the parties and an amount in controversy above $75,000. Because Autel removed the case, it had the burden to prove by a preponderance of the evidence—that the required facts were more likely than not true—that the jurisdictional amount was satisfied.
Jurisdictional Dispute
The court ordered Autel to explain why the case should not be sent back to state court. Autel relied on allegations in the complaint, Cao’s unpaid bonus, statutory penalties, and its own calculations. Autel attached Cao’s offer letter, which listed potential annual bonuses ranging from $22,000 to $42,000, but it did not provide the calculations it relied on.
At a final pretrial conference, the parties agreed that the estimated relief was approximately $73,173. That estimate included a maximum bonus of $32,000, approximately $26,539 in waiting-time penalties, and approximately $14,634 in attorneys’ fees, calculated as 25 percent of total costs. The court also invited the parties to provide additional calculations or information. Autel did not provide additional arguments or evidence, and the court stated that Autel appeared to concede the issue through silence.
Ruling
The court concluded that Autel had not proved by a preponderance of the evidence that the amount in controversy met the jurisdictional threshold. The court found that conclusory statements about Cao’s allegations and Autel’s own calculations were insufficient, particularly because Autel did not submit those calculations.
The court found that Autel had failed to establish subject-matter jurisdiction and remanded the case to state court. This was a jurisdictional ruling and did not decide the underlying contract or labor-law claims.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.