Tracy Fowler v. Wells Fargo Bank, N.A., 2:25-cv-06256

Wells Fargo removed a state-court fraud case to federal court, invoking diversity jurisdiction and alleging $135,000,000 in damages.
Plaintiff’s complaint alleges roughly $30,000 in actual economic loss (specific sums ~ $13,909.72 and additional sums believed > $17,000).
Plaintiff filed a Statement of Damages claiming $135,000,000 (special, general, and punitive damages), but counsel conceded those figures were chosen to meet a state-court threshold and not as a realistic valuation.
The removing defendant bears the burden to show by a preponderance that the amount in controversy exceeds $75,000 when the complaint does not clearly do so.
The court found the complaint does not establish the jurisdictional amount and the Statement of Damages, given counsel’s concession, is not persuasive evidence that the amount-in-controversy requirement is met.
The court ordered Wells Fargo to show cause in writing by September 8, 2025 why the case should remain in federal court and set the matter for discussion at the September 9, 2025 hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the amount in controversy exceeds $75,000 for diversity jurisdiction	Plaintiff’s Statement of Damages asserts $135,000,000 (special, general, punitive damages)	Removal notice relied on the $135,000,000 figure to invoke diversity jurisdiction	Complaint alleges ~ $30,000 loss; court finds no reliable evidence that amount in controversy exceeds $75,000 and orders defendant to show cause
Whether plaintiff’s filed damages statement can be treated as good-faith evidence of amount in controversy	Plaintiff presented the statement of damages as filed in state court	Defendant relied on that statement for removal	Court refuses to treat the statement as sufficient evidence because counsel conceded amounts were not realistic valuations

Snell v. Cleveland, Inc., 316 F.3d 822 (9th Cir. 2002) (federal courts may raise subject matter jurisdiction sua sponte)
Sky-Med, Inc. v. Fed. Aviation Admin., 965 F.3d 960 (9th Cir. 2020) (amount in controversy generally determined from the face of the complaint)
Ibarra v. Manheim Investments, Inc., 775 F.3d 1193 (9th Cir. 2015) (removing party must show amount in controversy by a preponderance when not clear from complaint)
Chavez v. JPMorgan Chase & Co., 888 F.3d 413 (9th Cir. 2018) (standard that removing party must show it is more likely than not amount in controversy exceeds jurisdictional threshold)
St. Paul Mercury Indem. Co. v. Red Cab Co., 303 U.S. 283 (1938) (if it is legally certain plaintiff cannot recover the claimed amount, diversity jurisdiction is lacking)