Sanjiv Goel M.D., Inc. v. Cigna Healthcare of California, Inc.

I. FACTUAL BACKGROUND

Plaintiff provides emergency medical services. Dkt. 1-1 (Compl.) § 1. After rendering such services to four patients insured by Defendants, Plaintiff submitted claims for reimbursement. Id. § 10. Defendants reimbursed Plaintiff $32,089.69 for those services but failed to reimburse the remaining $387,412.23 Plaintiff claims it is owed. Id. § 15.

II. DISCUSSION

A. Diversity Jurisdiction

Federal courts have diversity jurisdiction where the amount in controversy exceeds $75,000 and the action is between citizens of different states. 28 U.S.C. §§ 1332, 1441. Defendants do not contest that Cigna California and Plaintiff are both citizens of California, but claim Cigna California was fraudulently joined.2 For purposes of diversity jurisdiction, the Court “may disregard the citizenship of a non-diverse defendant who has been fraudulently joined.” Grancare, LLC v. Thrower, 889 F.3d 543, 548 (9th Cir. 2018). A non-diverse defendant is fraudulently joined “[i]f the plaintiff fails to state a cause of action against [the] resident defendant, and the failure is obvious according to the settled rules of the state.” Morris v. Princess Cruises, Inc.,…