Lin v. Amazon.com Services LLC

Background

Tao Lin originally filed a form complaint against Amazon.com Services LLC in Santa Clara County Superior Court. He alleged that Amazon breached an employment contract by refusing to sign an employment verification letter required under Amazon’s employment offer, and that Amazon engaged in retaliation and harassment.

The original complaint sought $1 million in damages and an injunction against further retaliation or harassment. After the state court sustained Amazon’s demurrer, Lin filed an amended complaint seeking the same remedies. Amazon then removed the case to federal court, relying only on diversity jurisdiction. Diversity jurisdiction allows a federal court to hear certain cases between citizens of different states when more than $75,000 is in dispute.

Amount in Controversy

The court held that the amount-in-controversy requirement was satisfied. Both the original and amended complaints requested $1 million. Although the court noted that this demand appeared disconnected from more specific amounts alleged in the amended complaint—including $8,597.30 in missed pay and other amounts involving $1,727.23 and $20,809.04—the court could not conclude with legal certainty that Lin could not recover more than $75,000.

The court also noted that Amazon had previously described the case in a case-management statement as a “limited case” involving $35,000 or less. But that fact did not change the court’s conclusion about the amount-in-controversy requirement.

Diversity of Citizenship

The parties agreed that Lin was a citizen of California. Amazon stated that it was incorporated in Delaware and that its principal place of business was in Seattle, Washington. A corporation is a citizen of its state of incorporation and the state containing its principal place of business.

The court ruled that Amazon did not meet its burden of proving its principal place of business. Amazon submitted no evidence supporting its statement that the principal place of business was in Seattle. Its conclusory statement in the removal notice was insufficient, and Amazon could not shift the burden to Lin by arguing that Lin had not disproved Amazon’s assertion.

The court declined to allow jurisdictional discovery before remand. It noted that Amazon had not requested discovery, that the relevant evidence was already under Amazon’s control, and that Amazon had chosen not to submit that evidence.

Procedural Arguments and Disposition

Amazon argued that Lin’s motion to remand did not comply with Civil Local Rule 7-2 because it did not include a noticed motion date, follow formatting requirements, or include a proposed order. The court declined to deny the motion on those grounds.

The court concluded that Amazon had not established federal subject-matter jurisdiction because it had not shown the required diversity of citizenship. It granted Lin’s motion to remand and remanded the case to Santa Clara County Superior Court. The order addressed removal and jurisdiction only; it did not decide whether Lin’s contract, retaliation, or harassment allegations were valid.