{"id":375,"date":"2026-01-06T12:00:00","date_gmt":"2026-01-06T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=375"},"modified":"2026-01-06T12:00:00","modified_gmt":"2026-01-06T12:00:00","slug":"angulo-santillano-wayfair-cd-cal-denies-remand-punitive-emotional-distress","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=375","title":{"rendered":"Angulo Santillano v. Wayfair LLC \u2014 C.D. Cal. Denies Remand of Wrongful-Termination Suit, Counting Punitive and Emotional-Distress Damages at 1:1 Ratios"},"content":{"rendered":"
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Case<\/dt>\n
Angulo Santillano v. Wayfair LLC<\/dd>\n
Court<\/dt>\n
U.S. District Court \u2014 Central District of California<\/dd>\n
Date Decided<\/dt>\n
2026-01-06<\/dd>\n
Docket No.<\/dt>\n
5:25-cv-02984<\/dd>\n
Status<\/dt>\n
Unreported \/ Non-Citable<\/dd>\n
Topics<\/dt>\n
Removal jurisdiction; FEHA wrongful termination; emotional-distress and punitive damages in amount-in-controversy; mitigation as affirmative defense<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

Vicente Martin Angulo Santillano sued Wayfair LLC in Riverside County Superior Court asserting California state-law claims for discrimination, wrongful termination, and related violations. He alleged that he was suspended and ultimately terminated in early 2025 after he sought time off and an intermittent leave of absence to take his prematurely born son to physical therapy. Wayfair removed the case on diversity grounds, claiming the amount in controversy exceeded $75,000 based on lost wages, emotional distress, punitive damages, and attorneys’ fees. Plaintiff moved to remand.<\/p>\n

The Court’s Holding<\/h2>\n

Judge Sunshine S. Sykes denied the motion to remand. Wayfair documented economic damages of $32,302.71 (33 weeks of past lost wages at $20.75\/hour), and plaintiff did not really dispute that figure. Plaintiff argued the lost-wages calculation should be reduced for his duty to mitigate, but the court applied Ninth Circuit precedent (Perez v. Alta-Dena Certified Dairy) that mitigation is an affirmative defense and therefore irrelevant to the amount-in-controversy calculation.<\/p>\n

For emotional distress damages, the court applied a 1:1 ratio to economic damages where the plaintiff has not provided his own estimate (Garfias v. Team Indus. Serv.). Wayfair did not need to cite analogous-case verdicts. For punitive damages, California law permits them in discrimination and wrongful-termination claims (Tameny v. Atlantic Richfield); courts often apply a 1:1 ratio to compensatory damages (Jackson v. Compass Group). Combining $32,302.71 in economic damages, $32,302.71 in emotional-distress damages, and $32,302.71 in punitive damages produced an amount in controversy of approximately $96,908.13 \u2014 comfortably above the $75,000 threshold even before considering attorneys’ fees. Removal was proper.<\/p>\n

Key Takeaways<\/h2>\n