An interesting remand case for you this morning, where a pro se plaintiff sought to remand her consumer-protection suit back to California state court on standing grounds, arguing she wasn’t harmed by the very thing she sued for.

In Baldi v. Service Finance Co. LLC (E.D. Cal. Sept. 23, 2025), the Eastern District of California denied pro se plaintiff Mary Catherine Baldi’s motion to remand her consumer protection case that had been properly removed from state court. The plaintiff, Mary Catherine Baldi, had financed HVAC equipment and after disputes with the Defendant lender alleged that she was wrongfully charged an additional $1,096.20 despite having paid the principal balance in full.

She further claimed that the company made 47 automated calls after she revoked consent, reported her account as delinquent to credit bureaus, and engaged in improper debt collection practices. On this basis, she asserted claims under the TCPA, FCRA, FDCPA, FCBA, and California’s Rosenthal Fair Debt Collection Practices Act.

Baldi sought remand by arguing that the i) Defendant’s notice of removal failed to establish Article III standing, ii) that state courts possess concurrent jurisdiction over the asserted federal statutes, iii) that the removal was a tactic to avoid state discovery rules, and iv) that her Rosenthal Act claims raised novel state-law issues that should predominate.

Service Finance argued it did not have the burden to establish Article III standing in its notice of removal. Defendant argued that the complaint itself raised clear federal questions — allegations under federal statutes FCRA, FDCPA, TCPA, and FCBA — which presented federal jurisdiction.

Defendant argued that Baldi’s reliance on concurrent jurisdiction was misplaced, emphasizing that once removal occurred, the state court’s authority ended. Defendant further argued that the Rosenthal Act claims are part of the same case or controversy, making supplemental jurisdiction proper.

The court rejected each of Plaintiff’s arguments:

Standing

First, it found that standing was satisfied because the complaint itself alleged concrete injuries sufficient to meet the Article III threshold and the removal notice was not required to provide a detailed standing analysis.

The Court found that although Baldi argued that FDCPA cases require a showing of concrete harm to establish standing in federal court, she never claimed that her own complaint failed to show such harm. In fact, her motion to remand pointed directly to her alleged injuries, including the rejection of her $8,504.65 payment, an unexplained $1,096.20 charge, 47 automated calls after she revoked consent, and negative credit reporting that led to a $13,000 credit line reduction.

In other words, Baldi’s motion undermined itself by arguing the need for concrete harm while simultaneously alleging just that in her complaint. And even Defendant who incorrectly denied the burden of proving standing, acknowledged that Baldi’s complaint alleged concrete injuries. Both parties effectively agreed that the complaint alleged enough facts to establish Article III standing.

Baldi also seemed to argue that by removing the case to federal court, Service Finance was admitting it had actually violated Federal law and caused her harm. The court made clear that isn’t how removal works. For Article III purposes, a plaintiff only needs to allege an injury tied to a federal statute — the defendant doesn’t have to concede those allegations are true in order to remove. The Ninth Circuit’s decision in Jones underscores this point — removal and jurisdiction can be proper even if the complaint is later dismissed for failing to allege a sufficient statutory injury under the relevant statute.

Thus the Court found Baldi’s complaint clearly alleged concrete injuries from Service Finance’s conduct, and she never argued otherwise in her motion to remand. Since the removal was based on those federal claims, the court found there was no basis to remand for lack of standing.

Concurrent Jurisdiction

Next, Baldi argued the case should return to state court because state courts share jurisdiction over statutes like the TCPA, FDCPA, FCBA and FCRA, but the court explained that concurrent jurisdiction only allows a case to start in state court — once properly removed, federal court maintains it.

Motion to Compel

Third, the court also dismissed Baldi’s arguments that the removal was intended to avoid state discovery obligations, holding that “fears of evidence spoilation” were speculative and that differences in state and federal discovery rules are not grounds for remand.

Supplemental Jurisdiction over Rosenthal Act Claims

Finally, the court concluded that the Rosenthal Act claims were factually intertwined with the federal causes of action – i.e. her allegations that defendant placed 47 automated calls and continued to contact her after being notified that she did not want to be contacted and failed to validate the debt she owed — making supplemental jurisdiction appropriate.

In the end, the court made clear that once a complaint raises federal claims like the TCPA, FCRA, or FDCPA, federal jurisdiction is appropriate. Standing only requires allegations of injury at the removal stage, and differences in state versus federal procedures are not enough to force a remand.