Griselda Jauregui v. Roadrunner Transportation Serv
28 F. 4th 989
| 9th Cir. | 2022Background
- Plaintiff Griselda Jauregui filed a putative California class action against Roadrunner alleging multiple wage-and-hour and related state-law violations on behalf of current and former California hourly workers.
- Roadrunner removed under the Class Action Fairness Act (CAFA) and produced payroll-based, summary-evidence estimates that the amount in controversy exceeded $5 million.
- The district court reviewed Roadrunner’s claim-by-claim calculations, accepted two claims (overtime and meal/rest break claims) totaling ~$2.1 million, and assigned a $0 valuation to five other claims where it disagreed with Roadrunner’s assumptions, then remanded for lack of CAFA jurisdiction.
- Roadrunner appealed, arguing the district court improperly applied an anti-removal posture and erred by zeroing-out disputed but reasonably supported claim valuations instead of adopting more conservative alternative assumptions.
- The Ninth Circuit reversed, holding the district court demanded undue certainty, misapplied CAFA principles, and should have valued claims under reasonable alternative assumptions; even using the lowest plausible wage figure, the minimum-wage claim plus the two accepted claims exceed $5 million.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper standard for CAFA removals | Remand was required because removal burden not met; court should strictly construe removal | CAFA has no anti-removal presumption; defendant’s factual estimate must be accepted unless contested | Court held CAFA should be read broadly; no anti-removal presumption and defendant’s reasonable assumptions deserve deference |
| Valuation method for amount in controversy | District court should reject overbroad assumptions and may assign $0 if defendant’s estimate is erroneous | Defendant may rely on reasonable assumptions and summary payroll evidence to estimate potential liability | Court held defendant may use a chain of reasonable assumptions; district court erred by demanding certitude and zeroing claims |
| Effect of disagreeing assumptions | If court disagrees it should reject the claim valuation entirely | If an alternative reasonable assumption exists, court should apply that alternative rather than zeroing out | Court ruled that preferring a different reasonable assumption justifies recalculation, not a $0 valuation |
| Whether CAFA threshold was met | Amount-in-controversy below $5M after rejecting defendant’s disputed assumptions | Even under conservative plausible assumptions (lowest wage used by district court), the minimum-wage claim plus accepted claims exceed $5M | Held CAFA jurisdiction exists; remand order reversed and case remanded for further proceedings |
Key Cases Cited
- Dart Cherokee Basin Operating Co. v. Owens, 574 U.S. 81 (2014) (no anti-removal presumption under CAFA; when amount is contested parties submit proof)
- LaCross v. Knight Transp. Inc., 775 F.3d 1200 (9th Cir. 2015) (reasonable assumptions may be used to estimate amount in controversy; courts should consider alternative plausible figures)
- Valdez v. Allstate Ins. Co., 372 F.3d 1115 (9th Cir. 2004) (removing party need not predict exact award; assumptions are acceptable)
- Theis Research, Inc. v. Brown & Bain, 400 F.3d 659 (9th Cir. 2005) (amount in controversy equals the amount at stake in the litigation)
- Greene v. Harley-Davidson, Inc., 965 F.3d 767 (9th Cir. 2020) (amount at stake refers to possible, not probable, liability)
- Fritsch v. Swift Transp. Co. of Ariz., 899 F.3d 785 (9th Cir. 2018) (remand orders under CAFA reviewed de novo)
- Arias v. Residence Inn by Marriott, 936 F.3d 920 (9th Cir. 2019) (strength of defenses bears on likelihood of recovery but not on amount at stake for jurisdictional purposes)