Jauregui v. Roadrunner Transp. Servs., Inc., 28 F.4th 989 (9th Cir. 2022)

Griselda Jauregui filed this putative class action in California state court against Roadrunner Transportation Services on behalf of all current and former hourly workers in California. The complaint alleged numerous violations of California wage and hour law. Roadrunner removed the case to federal court, invoking the Class Action Fairness Act (“CAFA”). Plaintiff filed a motion to remand on the ground that Roadrunner had failed to establish the requisite $5 million jurisdictional minimum for the amount in controversy under CAFA. In support of its opposition to the motion to remand, Roadrunner relied primarily on the declaration of its senior payroll lead who concluded, based upon the company’s payroll data and Jauregui’s allegations, the amount in controversy exceeded $14.7 million. The district court granted the motion to remand after independently evaluating Roadrunner’s calculations for each of the seven alleged violations. The district court found that Roadrunner had sufficiently demonstrated the claimed amount in controversy for only two of the seven claims and, as for the remaining five claims, the district court assigned a value of $0 for the amount in controversy where it disagreed with Roadrunner’s calculations. The Ninth Circuit reversed, holding that the district court committed “two primary errors”: (1) putting a thumb on the scale against removal; and (2) assigning a $0 amount to most of the claims simply because the lower court disagreed with one or more of the assumptions underlying Roadrunner’s amount in controversy estimates.