Stassa v. Target Corporation

Background

Randi Stassa brought a negligence action in New York State Supreme Court, Orange County, against Pyramid Management Group, LLC, Crystal Run Newco, LLC, and Target Corporation. She alleged that she slipped and fell on water inside a Target store in Middletown, New York, on March 29, 2022. She alleged that the defendants owned, leased, managed, operated, maintained, or otherwise had responsibility for the property.

The defendants moved the case to federal court based on diversity jurisdiction, which generally requires the parties to be citizens of different states and the amount in dispute to exceed $75,000. They argued that although Stassa, Pyramid, and Crystal Run were citizens of New York, Pyramid and Crystal Run had been improperly added solely to defeat federal jurisdiction because Stassa had no viable claim against them.

Legal standard

On a motion to remand, the party invoking federal jurisdiction bears the burden of showing that the case belongs in federal court. A defendant claiming improper or fraudulent joinder must provide clear and convincing evidence either that the plaintiff committed outright fraud in the pleadings or that there is no possibility that the plaintiff could state a claim against the nondiverse defendant under state law. Doubts and factual or legal uncertainties must be resolved in favor of the plaintiff.

Court’s analysis

The defendants relied on a ground lease. One provision required Target, as tenant, to maintain the store premises. Another provision required Crystal Run, as landlord, to maintain, repair, replace, and operate the shopping center’s common areas. The lease also required Crystal Run to protect and indemnify Target for claims connected with Crystal Run’s performance or failure to perform its maintenance obligations concerning the common areas.

The court concluded that the lease clearly assigned Target responsibility for the interior of the premises but also showed that Crystal Run retained some control and responsibility for the common areas. Stassa stated that after she fell, she felt water dripping on her and saw water coming from the ceiling. The court determined that the source of the water remained unknown and that the lease did not specifically identify which defendant was responsible for maintaining the roof, which could have been the source of the leak.

Because the lease was ambiguous and the available facts left open a possible claim against Crystal Run, the court could not find that there was no possible set of facts under which Stassa could recover from it. The court therefore found that the defendants had not proved that Pyramid and Crystal Run were improperly joined. The court distinguished a prior case because the lease there expressly excluded the nondiverse defendant from responsibility for the relevant interior areas, while the lease here was not unambiguous.

Disposition

The court GRANTED Stassa’s motion to remand. It directed the Clerk to remand the action to New York State Supreme Court, Orange County, and to terminate the motion at ECF No. 12. The opinion addressed federal jurisdiction and remand; it did not determine liability for Stassa’s injuries or decide the negligence claim on the merits.