Automated Summary
Key Facts
Plaintiff Sara Muñoz-Meléndez filed a complaint in Puerto Rico court against Dillard-Lewis, Inc. on June 12, 2025, alleging discrimination and harassment based on age, race, and gender, as well as retaliatory termination. The defendant removed the case to federal court on July 11, 2025, citing diversity jurisdiction, a federal question under the Age Discrimination in Employment Act (ADEA), and supplemental jurisdiction. Plaintiff later filed an Amended Complaint dropping her ADEA claim. The court determined that Plaintiff is a citizen of Puerto Rico, Defendant is a citizen of North Carolina, and the amount in controversy exceeds $75,000. These findings establish complete diversity and federal jurisdiction, resulting in the denial of the motion to remand.
Issues
- The court evaluated whether the Plaintiff's ADEA claim established federal-question jurisdiction, which would allow the case to remain in federal court. The Plaintiff initially included the ADEA claim but later sought to withdraw it via an amended complaint. The Defendant argued that the ADEA claim alone justified federal jurisdiction, while the Plaintiff contended it was subsidiary and that remand was appropriate once it was dropped.
- The court determined that complete diversity of citizenship exists between the parties. The Plaintiff is a citizen of Puerto Rico, and the Defendant, a corporation, is deemed a citizen of North Carolina (its state of incorporation and principal place of business). This satisfies the requirement that no plaintiff shares citizenship with any defendant under 28 U.S.C. § 1332.
- The court found that the amount in controversy clearly exceeds $75,000. The Plaintiff alleged damages totaling over $250,000 for retaliation and $200,000 for age discrimination under Puerto Rico and federal law. These claims, even after dropping the ADEA claim, establish the monetary threshold required for diversity jurisdiction under 28 U.S.C. § 1332.
Holdings
The Court denies Plaintiff's Motion to Remand, concluding that complete diversity jurisdiction exists between Plaintiff (Puerto Rico citizen) and Defendant (North Carolina corporation) and the amount in controversy exceeds $75,000. The decision emphasizes that the federal court has original jurisdiction over the case despite Plaintiff's withdrawal of the ADEA claim.
Legal Principles
- The court applied the 'complete diversity' requirement under 28 U.S.C. § 1332, determining that all plaintiffs and defendants must be citizens of different states (or territories, including Puerto Rico) for federal diversity jurisdiction to exist. This principle was uncontested in the record and formed the basis for denying the motion to remand.
- The court emphasized that the removing party (Dillard-Lewis) bears the burden of proving the propriety of removal under 28 U.S.C. § 1441(a). This principle was central to the analysis, as the plaintiff did not contest the defendant’s factual assertions about citizenship or jurisdictional amount.
Precedent Name
- Villegas v. Magic Transp., Inc.
- Lundquist v. Precision Valley Aviation, Inc.
- BRT Mgmt. LLC v. Malden Storage LLC
- Vitalife Inc. v. Keller Med., Inc.
- Danca v. Priv. Health Care Sys.
- Rodriguez-Diaz v. Sierra-Martinez
Cited Statute
- Puerto Rico Act 100
- Puerto Rico Act 115
- 28 U.S.C. § 1441(a)
- Age Discrimination in Employment Act
- Puerto Rico Act 80
- 28 U.S.C. § 1332
Judge Name
RAÚL M. ARIAS-MARXUACH
Passage Text
- Plaintiff's Amended Complaint references several sources of alleged damages that together constitute the amount in controversy... Hence, it is facially apparent from the Amended Complaint that the amount in controversy exceeds $75,000.
- Dillard-Lewis avers that its state of incorporation and principal place of business are both in North Carolina. (Docket Nos. 1 at 6, 22 at 2). It includes a statement under penalty of perjury from its Vice President, Steven Hester, which attests to these facts. (Docket No. 1-1 at 2).
- Plaintiff acknowledges in her Amended Complaint that she is a resident of Coamo, Puerto Rico. (Docket No. 35 at 1). In other filings, she similarly admits that it is an 'unequivocal fact that she is a resident of Puerto Rico.' (Docket No. 41 at 5).