833 F. Supp. 2d 1324
M.D. Ala.2011Background
- This is a class action by Alabama funeral-home employees seeking unpaid wages against SCI and related defendants.
- The case was removed to federal court under CAFA and the plaintiffs moved to remand.
- The central issue is whether CAFA’s $5,000,000 amount-in-controversy requirement is satisfied.
- The court finds the plaintiffs assert Alabama-only claims, not nationwide claims.
- There are 507 Alabama employees; the court must determine if aggregation yields over $5,000,000 in controversy.
- The court remands, concluding the amount in controversy is less than $5,000,000.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| CAFA threshold met for removal? | Plaintiffs contend the $5M threshold is not met. | SCI argues aggregated Alabama claims exceed $5M. | Not met; remand granted. |
| Are claims limited to Alabama employees? | Plaintiffs show claims are Alabama-based. | SCI argues nationwide class. | Alabama-only claims established. |
| Is 507 Alabama employees sufficient for aggregation under CAFA? | Not expressly disputed; aggregation possible. | Aggregation shows potential >$5M. | Aggregation does not demonstrate >$5M given evidence. |
| Do external cases/settlements compel CAFA jurisdiction? | Evidence from other cases may support jurisdiction. | Those cases are not sufficiently factually similar. | Not persuasive; not controlling for CAFA threshold. |
| Should attorneys’ fees, punitive damages, or injunctive relief be included? | Generally not included unless statute/contract allows. | Not enough to push over $5M; still not met. |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (U.S. 1994) (federal court jurisdiction is limited to what Congress enacts)
- Pretka v. Kolter City Plaza II, Inc., 608 F.3d 744 (11th Cir. 2010) (broad evidentiary scope for CAFA removal; may use non-pleaded facts and extrapolations)
- Williams v. Best Buy Co., Inc., 269 F.3d 1316 (11th Cir. 2001) (burden on defendant to prove $5M threshold when not facially apparent)
- Lowery v. Alabama Power Co., 483 F.3d 1184 (11th Cir. 2007) (outside-source evidence in § 1446(b) context; distinctions noted)
- Thomas v. Bank of America Corp., 570 F.3d 1280 (11th Cir. 2009) (CAFA removal requirements: minimal diversity, numerosity, commonality)