Spiegel v. Estee Lauder Inc.
- Denise Cote
- 1:23-cv-11209
- U.S. District Court · Southern District of New York
- 5
In Spiegel v. Estée Lauder Inc., Judge Cote denied remand because the complaint included federal claims supporting removal.
Theresa Spiegel and the defendants, including Estée Lauder Inc., Estée Lauder Companies, Inc., ELC Beauty LLC, Estée Lauder International Inc., Lusine Jacobs, Noe Arteaga, Angelina Miller, and Jenne Eugene. The case remains in federal court.
What happened
Spiegel v. Estée Lauder Inc. began in New York state court and concerns Theresa Spiegel’s alleged employment and termination. Her complaint included six claims, including one under the Fair Labor Standards Act and two under 42 U.S.C. § 1981.
The defendants moved the case to federal court, and Spiegel asked the court to send it back to state court. She argued that her state-law claims were the main claims and that New York law allowed greater liquidated damages, but the court rejected both arguments.
Judge Denise Cote denied Spiegel’s motion to remand. The court held that one federal claim was enough to support removal and that the federal court could apply New York law to the state-law claims, including any warranted liquidated damages.
The detailed version
- Spiegel v. Estee Lauder Inc. · No. 1:23-cv-11209
- Denise Cote
- Apr. 17, 2024
Background
Theresa Spiegel filed this employment-related action in New York Supreme Court on or about November 28, 2023. The complaint asserted six causes of action concerning her alleged employment with ELC Beauty LLC and the termination of that employment. Three claims arose under federal law: one under the Fair Labor Standards Act of 1938, 29 U.S.C. § 206, and two under 42 U.S.C. § 1981.
The defendants removed the action to the U.S. District Court for the Southern District of New York on December 27, 2023, relying on federal-question jurisdiction. Spiegel moved to remand the case to state court on January 22, 2024.
Court’s analysis
The court explained that a state-court case may be removed when it could originally have been filed in federal court. A single claim within federal-question jurisdiction is enough to permit removal. Federal-question jurisdiction generally exists when a federal issue appears on the face of the plaintiff’s properly pleaded complaint.
The court held that removal was proper because Spiegel asserted three federal-law claims. It rejected Spiegel’s argument that her state-law tort claims were the main or most substantial part of the case, explaining that federal claims do not have to predominate over state-law claims for removal to be proper.
The court also rejected Spiegel’s argument based on the possibility of greater liquidated damages under the New York Labor Law. Under the Erie doctrine, a federal court applies state law to state-law claims. The court therefore explained that it could award liquidated damages under New York law if they were warranted, while noting that Spiegel had abandoned this argument in her reply.
Ruling
Judge Denise Cote denied Spiegel’s January 22, 2024 motion to remand. The opinion does not decide whether Spiegel will ultimately prevail on her employment claims; it decides only that the case was properly removed to federal court.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.