Joecelyn Jefferson v. Walmart Inc., 5:25-cv-00146

Plaintiff sued Walmart for severe and permanent injuries allegedly caused by a Walmart employee's negligent conduct.
The Complaint described significant injuries, ongoing medical treatment, disability, and loss of earning capacity, but did not specify a dollar amount.
Plaintiff later served a Statement of Damages alleging $30 million in damages, more than 400 times the jurisdictional minimum for federal diversity jurisdiction ($75,000).
Walmart removed the case to federal court on January 17, 2025, claiming they did not have notice it was removable until receiving Plaintiff’s medical bills on January 9, 2025.
Plaintiff moved to remand, arguing that Walmart’s removal was untimely because the 30-day window started with service of the Statement of Damages on October 29, 2024.
The Court ruled on the timeliness of removal and whether the statement of damages gave Walmart adequate notice of removability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When did 30-day removal clock start?	Statutory period began with Statement of Damages	Did not have enough info until medical bills	Clock started with Statement of Damages
Was Statement of Damages sufficient notice?	Yes: $30 million claimed shows removability	Statement not itemized/just “bold prediction”	Statement was adequate, direct evidence
Did Walmart remove timely?	No: missed 30-day statutory window	Yes: filed within 30 days of medical bill receipt	No: removal was untimely
Proper action/remedy	Remand to state court required	Case should stay in federal court	Remand to state court ordered

Caterpillar, Inc. v. Williams, 482 U.S. 386 (federal removal jurisdiction standards)
Gaus v. Miles, Inc., 980 F.2d 564 (strong presumption against removal jurisdiction; defendant’s burden)
Gunn v. Minton, 568 U.S. 251 (federal courts’ limited jurisdiction)
Gebbia v. Wal-Mart Stores, Inc., 233 F.3d 880 (amount in controversy satisfied by severe injury allegations)