Madison Levin v. Jomashop, Inc.
2:25-cv-02523
C.D. Cal.May 22, 2025Background
- Madison Levin (Plaintiff) filed a putative class action against Jomashop, Inc. (Defendant) in the U.S. District Court for the Central District of California.
- The Complaint alleges federal jurisdiction under the Class Action Fairness Act (CAFA), which requires the amount in controversy to exceed $5 million, diversity of citizenship, and a class of at least 100 members.
- The Court reviewed the Complaint and could not determine if the amount in controversy exceeds $5 million, as required by CAFA.
- The parties are ordered to show cause, in writing, why the case should not be dismissed for lack of subject matter jurisdiction.
- The Plaintiffs bear the burden of proving federal jurisdiction, specifically that the CAFA threshold is met.
- If the Plaintiff does not respond adequately and timely, the court will dismiss the action without further notice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject Matter Jurisdiction under CAFA | Jurisdiction proper | Jurisdiction improper | Court uncertain; parties must submit proof on amount in controversy |
| Amount in Controversy Exceeds $5 Million | Not fully addressed yet | Not fully addressed yet | Court finds Complaint lacks sufficient allegations/proof of required amount |
| Sufficiency of Jurisdictional Allegations | Federal jurisdiction exists | Federal jurisdiction does not exist | Plaintiff must provide sufficient facial and factual evidence |
| Burden of Proof on Jurisdiction | Not directly addressed | Not directly addressed | Plaintiff must show subject matter jurisdiction by a preponderance of evidence |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (1994) (federal courts are of limited jurisdiction and jurisdiction must be affirmatively shown)
- DaimlerChrysler Corp. v. Cuno, 547 U.S. 332 (2006) (jurisdiction presumed lacking unless proven otherwise)
- Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574 (1999) (court must examine jurisdiction before merits)
- Dart Cherokee Basin Operating Co. v. Owens, 574 U.S. 81 (2014) (pleading requirement and burden of proof for amount in controversy under CAFA)
- Leite v. Crane Co., 749 F.3d 1117 (9th Cir. 2014) (standard for evaluating jurisdictional allegations)