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Lacross v. Knight Transp. Inc.

United States Court of Appeals, Ninth Circuit

January 8, 2015

PATRICK LACROSS; ROBERT LIRA; MATTHEW LOFTON, on behalf of themselves and all others similarly situated, Plaintiffs-Appellees,
v.
KNIGHT TRANSPORTATION INC., an Arizona Corporation; KNIGHT TRUCK AND TRAILER SALES, LLC, an Arizona Limited Liability Company, Defendants-Appellants

Argued and Submitted, Pasadena, California December 8, 2014.

Appeal from the United States District Court for the Central District of California. D.C. No. 5:14-cv-00771-JGB-JC. Jesus G. Bernal, District Judge, Presiding.

SUMMARY[*]

Class Action Fairness Act / Amount in Controversy

The panel reversed the district court's judgment remanding the putative class action to state court, and held that the defendants Knight Transportation, Inc., and Knight Truck and Trailer Sales had shown that they were entitled under the Class Action Fairness Act to proceed in federal court because they had established the requisite $5 million amount in controversy.

The plaintiff putative class of truck drivers alleged that Knight misclassified them as independent contractors and asserted other labor law violations, and filed their action in California state court. Knight removed the case to federal court and estimated the amount in controversy for reimbursing the drivers' lease-related and fuel costs to be at least $44 million

In Ibarra v. Manheim Investments, Inc., __ F.3d __. No. 14-56779, 775 F.3d 1193, (9th Cir. Jan. 8, 2015), filed simultaneously with this opinion, the panel held that when a defendant relies on a chain of reasoning that includes assumptions to satisfy its burden to prove by a preponderance of the evidence that the amount in controversy exceeded $5 million, the chain of reasoning and its underlying assumptions must be reasonable.

The panel applied the framework of analysis in Ibarra to defendants' proof, and concluded that defendants had met their burden of proof because defendants relied on a reasonable chain of logic and presented sufficient evidence to establish that the amount in controversy exceeded $5 million.

Richard H. Rahm (argued), James E. Hart, Carly Nese, and Thomas J. Whiteside, Littler Mendelson, P.C., San Francisco, California, for Defendants-Appellants.

James M. Trush (argued), Trush Law Office, Costa Mesa, California; Ellen R. Serbin, Todd H. Harrison, and Brennan S. Kahn, Perona, Langer, Beck, Serbin, Mendoza & Harrison, APC, Long Beach, California, for Plaintiffs-Appellees.

Before: Susan P. Graber, Ronald M. Gould, and Consuelo M. Callahan, Circuit Judges. Opinion by Judge Gould.

OPINION

Page 1201

GOULD, Circuit Judge:

With this appeal pending, we decided Ibarra v. Manheim Investments, Inc., __ F.3d __, No. 14-56779, 775 F.3d 1193, (9th Cir. Jan. 8, 2015), filed simultaneously with this opinion, and addressed what proof a defendant seeking removal must produce to prove the amount in controversy requirement under the Class Action Fairness Act of 2005 (" CAFA" ), 28 U.S.C. § 1332(d), when the complaint does not include a facially apparent amount in controversy or may have understated the true amount in controversy. We held in Ibarra that when the defendant relies on a chain of reasoning that includes assumptions to satisfy its burden to prove by a preponderance of the that the amount in controversy exceeds $5 million, the chain of reasoning and its underlying assumptions must be reasonable. Ibarra, __ F.3d. at __, *14. We apply our framework of analysis in Ibarra to defendants' proof here and conclude that because defendants relied on a reasonable chain of logic and presented sufficient evidence to establish that the amount in ...


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