Henry Mauriss v. JPMorgan Chase Bank, National Association, 8:17-cv-00678

Plaintiff Henry Mauriss executed a Deed of Trust in 2007 for a $450,000 loan secured by his primary residence.
Mauriss fell behind on payments after June 2016 due to medical and employment-related hardship and submitted a completed loan-modification package in late September 2016.
JPMorgan allegedly did not acknowledge receipt or communicate about the modification; a Notice of Default was recorded December 20, 2016.
Mauriss sued in Orange County Superior Court (March 2017) for violations of the California Homeowner’s Bill of Rights, unfair business practices, breach of the covenant of good faith and fair dealing, and negligence, seeking injunctive relief and damages (not rescission or quiet title).
JPMorgan removed the case to federal court asserting diversity jurisdiction; Mauriss moved to remand, arguing the amount-in-controversy requirement is not met.
The district court granted remand, holding JPMorgan failed to show by a preponderance of the evidence that the amount in controversy exceeded $75,000 given the relief sought.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether diversity jurisdiction exists (amount-in-controversy)	Mauriss: relief sought is loan modification/limited injunctive relief and statutory damages; not seeking rescission or title, so amount in controversy is not the loan or property value	JPMorgan: injunctive relief could implicate the loan amount or property value, so amount-in-controversy exceeds $75,000	Held: JPMorgan did not meet its burden to show > $75,000; remand required
Proper measure of amount-in-controversy for injunctive relief tied to loan modification	Mauriss: measure should be limited (e.g., temporary relief equivalent to costs or rental-value analog), not full loan or property value	JPMorgan: full loan balance or property value is a permissible measure when injunction affects the property/loan	Held: Where plaintiff seeks only temporary relief to obtain a loan modification, the court will not treat the full loan or property value as the amount in controversy absent evidence; temporary injunctive relief likely far less than $75,000

Williams v. Costco Wholesale Corp., 471 F.3d 975 (9th Cir. 2006) (removability judged by state-court pleadings at time of removal)
Hunter v. Philip Morris USA, 582 F.3d 1039 (9th Cir. 2009) (burden rests on party asserting federal jurisdiction)
Abrego Abrego v. Dow Chem. Co., 443 F.3d 676 (9th Cir. 2006) (presumption against federal jurisdiction)
Kroske v. U.S. Bank Corp., 432 F.3d 976 (9th Cir. 2005) (defendant must prove amount-in-controversy by preponderance when complaint does not specify damages)
Singer v. State Farm Mut. Auto. Ins. Co., 116 F.3d 373 (9th Cir. 1997) (requiring evidentiary showing when amount in controversy is disputed)
Matheson v. Progressive Specialty Ins. Co., 319 F.3d 1089 (9th Cir. 2003) (conclusory allegations insufficient to establish amount in controversy)
Ibarra v. Manheim Investments, Inc., 775 F.3d 1193 (9th Cir. 2015) (must submit evidence, not speculation, to establish amount in controversy)
Gaus v. Miles, Inc., 980 F.2d 564 (9th Cir. 1992) (removal statute strictly construed)
Morris v. Princess Cruises, Inc., 236 F.3d 1061 (9th Cir. 2001) (complete diversity requirement explained)