Rankins v. United Parcel Service, Inc.
- Jacquelyn Corley
- 3:23-cv-05785
- U.S. District Court · Northern District of California
- 4
In Rankins v. United Parcel Service, Inc., Judge Corley denied remand because the parties were citizens of different states and the claims exceeded $75,000.
Tami Rankins and United Parcel Service, Inc.; the case remained in federal court, and the court did not decide the merits of Rankins’s claims.
What happened
In Rankins v. United Parcel Service, Inc., Tami Rankins sued United Parcel Service, Inc. in California state court, alleging discrimination, harassment, wage theft, emotional distress, and breach of contract under California law. UPS moved the case to federal court, and Rankins asked the court to send it back to state court.
The court denied Rankins’s motion to remand. It found that the parties were citizens of different states for federal jurisdiction purposes: Rankins was a California citizen, while UPS was incorporated in Ohio and had its principal place of business in Georgia. The court also found that the amount at stake was more than $75,000 based on the alleged damages, attorney’s fees, and possible punitive damages.
The court did not decide whether Rankins’s claims were valid. Judge Jacquelyn Scott Corley also denied Rankins’s request for attorney’s fees and costs because the case was not remanded.
The detailed version
- Rankins v. United Parcel Service, Inc. · No. 3:23-cv-05785
- Jacquelyn Corley
- Dec. 22, 2023
Background
Tami Rankins sued United Parcel Service, Inc. in California state court. She alleged that UPS engaged in systemic discrimination, harassment, and wage theft in violation of California law. Her five claims were: disparate treatment in violation of public policy; harassment based on gender and age; failure to prevent discrimination; intentional infliction of emotional distress; and breach of contract.
UPS removed the case to federal court, asserting diversity jurisdiction and federal-question jurisdiction. Rankins moved to remand, meaning she asked the federal court to return the case to state court. She also requested attorney’s fees and costs.
Court’s Analysis
The court held that diversity jurisdiction existed. Diversity jurisdiction requires that the parties be citizens of different states and that the amount in controversy exceed $75,000. The court found that Rankins was a citizen of California. It found that UPS was incorporated in Ohio and had its principal place of business in Georgia. The parties therefore were completely diverse.
The court also found that UPS established that more than $75,000 was in controversy. Rankins did not request a specific dollar amount, but her complaint alleged more than five years of verbal assaults and threats, financial harm, lost earnings and benefits, humiliation, emotional and physical anguish, deterioration of health, and loss of a job. The court also considered her requests for attorney’s fees and punitive damages. Based on these allegations and requests, the court concluded that the amount in controversy was more likely than not above $75,000.
Because diversity jurisdiction was established, the court did not decide whether federal-question jurisdiction also existed. The court did not address the merits of Rankins’s underlying claims.
Ruling
The court denied Rankins’s motion to remand. It also denied her request for attorney’s fees and costs because the motion was denied and the case was not remanded. The order disposed of Docket Number 16.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.