{"id":417,"date":"2026-01-08T12:00:00","date_gmt":"2026-01-08T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=417"},"modified":"2026-01-08T12:00:00","modified_gmt":"2026-01-08T12:00:00","slug":"yamamoto-fedex-cd-cal-denies-remand-cafa-class-action","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=417","title":{"rendered":"Yamamoto v. Federal Express Corp. \u2014 C.D. Cal. Denies Remand of Class-Action Wage Suit Where CAFA Amount in Controversy and Diversity Are Established"},"content":{"rendered":"
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Case<\/dt>\n
Yamamoto v. Federal Express Corp.<\/dd>\n
Court<\/dt>\n
U.S. District Court \u2014 Central District of California<\/dd>\n
Date Decided<\/dt>\n
2026-01-08<\/dd>\n
Docket No.<\/dt>\n
2:25-cv-06796<\/dd>\n
Status<\/dt>\n
Unreported \/ Non-Citable<\/dd>\n
Topics<\/dt>\n
Class Action Fairness Act (CAFA); minimal diversity; $5 million amount-in-controversy; equitable jurisdiction over UCL claims; piecemeal remand<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

Michael Yamamoto filed a putative class action against FedEx Corporation and Federal Express Corporation in Los Angeles County Superior Court asserting wage-and-hour and California Business & Professions Code \u00a7 17200 (UCL) claims, including failure to pay overtime, minimum, and final wages, wage statement violations, and violation of Labor Code \u00a7 227.3. Defendants removed under the Class Action Fairness Act (CAFA), 28 U.S.C. \u00a7 1332(d). Yamamoto moved to remand, challenging both minimal diversity and the $5 million amount-in-controversy threshold.<\/p>\n

The Court’s Holding<\/h2>\n

Judge Percy Anderson denied the motion to remand. On minimal diversity, the court accepted the Notice of Removal’s allegations: Yamamoto is a California citizen, and FedEx and Federal Express are citizens of Delaware and Tennessee. CAFA only requires that any one plaintiff be diverse from any one defendant.<\/p>\n

On amount in controversy, defendants’ calculations using conservative assumptions about the class size, hourly rates, and per-employee damages exceeded the $5 million threshold. The court noted that defendants’ assumptions were actually quite conservative compared to the actual workforce data \u2014 affected employees earned at least $15\/hour, part-time workers were guaranteed at least 3.5 hours per day, and 20% of workers were full-time. Yamamoto’s argument that some claims were barred by a release from a prior class action was irrelevant under Arias v. Residence Inn by Marriott \u2014 the strength of defenses goes to merits, not to amount in controversy.<\/p>\n

On Yamamoto’s argument that the court should remand the UCL claim for lack of equitable jurisdiction (citing Sonner v. Premier Nutrition), the court held that Sonner’s rule against equitable jurisdiction over restitution-only claims did not apply because Yamamoto also sought prospective injunctive relief, distinguishing Steen v. American National Insurance. Even if equitable jurisdiction were lacking, the court noted that 28 U.S.C. \u00a7 1447(c) authorizes remand of an entire case but not piecemeal remand of individual claims.<\/p>\n

Key Takeaways<\/h2>\n