Eduardo Garcia v. William Scotsman Inc., 2:24-cv-02977

Plaintiff Eduardo Garcia filed a class action in California state court alleging various wage-and-hour violations against his employer, William Scotsman, Inc.
Alleged claims included failure to pay minimum and overtime wages, provide meal and rest breaks, timely final wages, accurate wage statements, reimburse expenses, and unfair business practices.
Defendant removed the case to federal court under the Class Action Fairness Act (CAFA), asserting the amount in controversy exceeded $5 million.
Plaintiff moved to remand, arguing Defendant failed to establish the requisite amount in controversy for federal jurisdiction under CAFA.
The Court considered whether Defendant met its burden to show, by a preponderance of the evidence, that the amount in controversy requirement was satisfied.
The Court denied Plaintiff’s motion to remand, finding removal appropriate under CAFA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adequacy of Evidence for Amount in Controversy	Defendant's declarations lack foundation and details, no business records provided	Relying on expert/HR declarations and payroll data is standard in wage class actions	Declarations sufficient, especially with supplemental information provided
Appropriateness of Assumptions for Damages	Violation rates, wage estimates, and assumptions too high and unsupported	Conservative assumptions, founded on complaint’s allegations and reasonable grounds	Defendant's assumptions reasonable and supported by complaint language
Calculation of Business Expense Damages	Defendant overstated amount, complaint reflects only occasional violations	Used standard $25/month per employee, as accepted in similar cases	Court used lower $5/month reflecting complaint language; still sufficient for jurisdiction
Attorneys’ Fees Inclusion	Should be limited or excluded from amount in controversy	Future fees are proper and plaintiff seeks them, so they must be considered	Attorneys’ fees must be included; even at low rates, threshold is met

Gunn v. Minton, 568 U.S. 251 (rule that federal courts have limited jurisdiction, must be authorized by statute or Constitution)
City of Chicago v. International College of Surgeons, 522 U.S. 156 (removal to federal court appropriate if original jurisdiction present)
Dart Cherokee Basin Operating Co. v. Owens, 574 U.S. 81 (CAFA removal requires only plausible claim initially, but more when contested)
Abrego Abrego v. Dow Chem. Co., 443 F.3d 676 (burden remains on removing party to show jurisdiction under CAFA)
Arias v. Residence Inn by Marriott, 936 F.3d 920 (permitting reasonable assumptions to estimate CAFA amount in controversy)
Jauregui v. Roadrunner Transp. Servs. Inc., 28 F.4th 989 (courts must not be skeptical about CAFA jurisdiction, and may reduce but not zero out estimates)
Fritsch v. Swift Transp. Co. of Arizona, LLC, 899 F.3d 785 (future attorneys’ fees must be included in amount in controversy under CAFA)