UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

REANETTA HUNT,

Plaintiff,

v. Case No. 25-cv-2671 (CRC)

LONITA KERMITTA BAKER,

Defendant.

MEMORANDUM OPINION

In early 2022, Reanetta Hunt was appointed as executive director and chief

administrative officer of the National Bar Association (“NBA” or “the Association”), a national

network of predominantly African American attorneys and judges. But her tenure as an NBA

executive was cut short, allegedly because of a “sustained pattern of tortious interference and

misuse of authority” by Lonita Baker, the former president of the NBA. Compl. ¶ 1. In her

complaint—which spans more than 200 pages, including 32 exhibits—Hunt describes a months-

long campaign by Baker to “centraliz[e] control,” “perpetuate[] dysfunction,” and “orchestrat[e]

maneuvers to force [Hunt’s] removal” from the NBA. Id. ¶¶ 12, 14, 18.

The issue presented here is not whether Hunt’s claims have merit; it is whether they may

be heard in this Court. Hunt filed this lawsuit in the Superior Court of the District of Columbia.

Baker then removed the case to federal court based on diversity jurisdiction. See

(a). Now, Hunt asks the Court to remand the case to the D.C. Superior Court because

there is insufficient evidence that the $75,000 “amount in controversy” requirement for diversity

jurisdiction is satisfied. The Court agrees, so it will grant Hunt’s motion to remand. I. Background

In January 2022, Hunt was chosen to serve as the NBA’s executive director and chief

administrative officer. Compl. ¶ 24. As executive director, Hunt would supervise the NBA’s

administrative staff, oversee the operation of the Association’s central office, and maintain the

Association’s records. Compl., Ex. K at 5. Hunt signed a three-year employment agreement

with the Association, which included a base salary of $200,000, health and retirement benefits,

and performance-based incentives. Compl. ¶ 25. She began work in March 2022.

Baker’s term as the NBA’s president did not begin until several months later.

.

But the complaint alleges that, as president-elect, Baker “launch[ed] a calculated campaign to

undermine [Hunt’s] leadership and ultimately orchestrate her removal.”

. As part of this

scheme, Baker purportedly (1) interfered with Hunt’s administrative duties; (2) assumed control

of the Association’s communications function; (3) undermined Hunt’s authority as executive

director; (4) falsely accused Hunt of disobeying the Association’s board of governors;

(5) fabricated a letter attacking Hunt’s professionalism; and (6) encouraged a part-time NBA

employee to file a complaint against Hunt. See

, 41–44, 65–67. According to

the complaint, Baker then arranged for Hunt to be placed on administrative leave—and

ultimately fired—by the Association’s board of governors in October 2022.

¶ 46–47.

After her termination, Hunt sought other employment opportunities. Specifically, she

“engaged in negotiations for a $260,000 consulting contract with the Pulaski County Sheriff’s

Office to develop a strategic communications and community engagement plan.”

. Hunt

claims that while her proposal was “initially well-received,” the Sheriff’s Office declined to

proceed because of “Baker’s dissemination of false and damaging narratives about [Hunt] within

her professional network.”

¶¶ 73–74.

2 In October 2023, Hunt filed a complaint advancing breach of contract and defamation

claims against the NBA and one of its contractors in D.C. Superior Court. See Complaint, Hunt

v. Nat’l Bar Ass’n, No. 2023-CAB-006395 (D.C. Super. Ct. Oct. 14, 2023). Hunt later added

Baker as a defendant, alleging that she engaged in retaliation, defamation, and tortious

interference with contractual relations. See First Amended Complaint, Hunt v. Nat’l Bar Ass’n,

No. 2023-CAB-006395 (D.C. Super. Ct. Oct. 23, 2024). Earlier this year, the D.C. Superior

Court dismissed Hunt’s claims against Baker because she failed to effectuate proper service. See

Omnibus Order at 16, Hunt v. Nat’l Bar Ass’n, No. 2023-CAB-006395 (D.C. Super. Ct. Feb. 27,

2025). Hunt’s breach of contract claim against the NBA—in which she seeks at least $500,000

in compensatory damages—remains pending. See Second Amended Complaint at 24, Hunt v.

Nat’l Bar Ass’n, No. 2023-CAB-006395 (D.C. Super. Ct. Mar. 3, 2025).

Hunt then filed this standalone action against Baker, again in D.C. Superior Court. The

complaint includes two claims. First, Hunt alleges that Baker tortiously interfered with her

contractual relationship with the NBA by “orchestrating a sustained campaign of obstruction and

sabotage” that resulted in her “wrongful[] terminat[ion] less than eight months into her three-

year term,” “the loss of substantial salary, benefits, professional opportunities,” and “reputational

harm.” Compl., Count I ¶ 4. Second, Hunt claims that Baker tortiously interfered with

prospective economic advantage by “disseminating false and retaliatory narratives about

[Hunt’s] performance and character, damaging her professional standing within the legal and

nonprofit communities.” Compl., Count II ¶ 4. Due to Baker’s interference, Hunt purportedly

“lost her employment and suffered diminished future earning potential, reputational harm, and

substantial emotional distress.”

. The complaint seeks an unspecified amount of

(1) compensatory damages “[f]or lost wages, benefits, professional opportunities, reputational

3 harm, emotional distress, and all other forms of direct and consequential loss”; (2) punitive

damages “[t]o penalize and deter” Baker’s conduct; (3) equitable relief “to restore [Hunt’s]

professional standing, reputation, and economic opportunities”; and (4) attorneys’ fees and costs.

Compl, Prayer for Relief.

In August 2025, Baker removed the case to this Court. She maintained that the Court has

diversity jurisdiction over the case because the parties were diverse and the amount in

controversy exceeded $75,000. See Notice of Removal ¶ 4;

(a). While

acknowledging that the complaint did not “expressly seek a stated sum of money damages,”

Baker asserted that it is “apparent from the face of the [c]omplaint” that Hunt seeks “well in

excess of $75,000[.]”

. Hunt now moves to remand the case to the D.C. Superior Court

because Baker “cannot establish that [Hunt] seeks more than $75,000 in this case.” Pl.’s Mot. to

Remand at 1–2. Hunt simultaneously filed a “stipulation regarding damages,” in which she

agrees to not seek, accept, or enforce any judgment for damages exceeding $75,000. Pl.’s

Stipulation Regarding Damages at 1–2. Baker opposes remand.

II. Legal Standards

When a plaintiff files a civil action in state court, a defendant generally may remove the

case to federal court if it falls within the federal court’s original jurisdiction. See

(a); District of Columbia v. Grp. Hospitalization & Med. Servs., Inc.,

(D.D.C. 2008). The defendant “bears the burden of establishing that federal jurisdiction

exists.” Zuckman v. Monster Beverage Corp.,

(D.D.C. 2013); see also

Bronner on Behalf of Am. Stud. Ass’n v. Duggan,

, 610 (D.C. Cir. 2020). This

Court “strictly construes removal status because of federalism concerns,” and the Court “must

resolve any ambiguities concerning the propriety of removal in favor of remand.” Johnson-

4 Brown v. 2200 M St. LLC,

(D.D.C. 2003). “When it appears that a

district court lacks subject matter jurisdiction over a case that has been removed from a state

court, the district court must remand the case[.]” Republic of Venezuela v. Philip Morris Inc.,

(D.C. Cir. 2002) (citing

(c)).

III. Analysis

Hunt’s motion to remand turns on whether the complaint establishes federal diversity

jurisdiction. Federal district courts have diversity jurisdiction over a civil action if “the matter in

controversy exceeds the sum or value of $75,000, exclusive of interest and costs, and is

between . . . citizens of different States.”

(a). The parties—and now the

Court—agree that Hunt and Baker are “diverse,” as they are citizens of different states. See Pl.’s

Mot. to Remand at 5; Def.’s Opp’n to Mot. to Remand at 4–5. The only remaining issue, then, is

whether the amount-in-controversy requirement is satisfied.

In her notice of removal, Baker submits that the amount in controversy is “well in excess

of $75,000.” Notice of Removal at 3. This claim “should be accepted when not contested by the

plaintiff or questioned by the court.” Dart Cherokee Basin Operating Co., LLC v. Owens,

, 87 (2014). But because Hunt disputes Baker’s assertion of the amount in controversy,

removal is proper only if the Court finds by a preponderance of the evidence that the amount in

controversy exceeds $75,000. See

(c)(2)(B); Gardner v. Erie Ins. Co.,

, 140 (D.D.C. 2022) (citing Dart Cherokee, 574 U.S. at 88). Both parties may

submit evidence, including affidavits and declarations, to support their respective claims. See

Gardner, 639 F. Supp. 3d at 140; Apton v. Volkswagen Grp. of Am., Inc.,

(D.D.C. 2017). Ultimately, Baker bears the burden of establishing that the amount in

5 controversy exceeds $75,000. See Sloan v. Soul Circus, Inc., No. 15-cv-1389,

, at *5 (D.D.C. Dec. 18, 2015).

Baker does not provide extrinsic evidence supporting her assertion that the Court has

jurisdiction over Hunt’s complaint. Instead, she contends that the complaint “on its face

conclusively establishes that at the time of removal the amount in controversy exceeded this

Court’s jurisdictional minimum.” Def.’s Opp’n to Mot. to Remand at 2. For the tortious

interference with contract claim, Baker notes that Hunt’s base annual salary was $200,000, and

the complaint alleges that “as a direct and proximate result of [Baker’s] tortious interference,

[Hunt] was wrongfully terminated less than eight months into her three-year term, resulting in

the loss of substantial salary, benefits, professional opportunities, and causing reputational

harm.”

at 5–6 (quoting Compl., Count I ¶ 4(g)). For the tortious interference with

prospective economic advantage claim, Baker points to the complaint’s allegation that the

Pulaski County Sheriff’s Office declined to award Hunt a $260,000 consulting contract because

of Baker’s “dissemination of false and damaging narratives.”

at 6–7 (citing Compl. ¶¶ 71,

73–74). Because Hunk seeks compensatory damages “from the loss of her $200,000 per year

employment contract and a $260,000 lost employment contract,” Baker says, the complaint

“conclusively establishes that . . . the amount in controversy requirement is easily met.”

.

But in Hunt’s view, the complaint does not “conclusively establish[]” any specific

amount of relief. Hunt first submits that the complaint “does not allege that [Baker] is

responsible for the full . . . value” of her NBA employment contract; it seeks only damages

caused by Baker’s tortious interference. Pl.’s Mot. to Remand at 5. She then notes that her

proposal to the Sheriff’s Office was “non-final,” and there is no evidence of the “net value” of

the contract or any “reasonable certainty” that Hunt would ultimately receive it. Pl.’s Reply in

6 Supp. of Mot. to Remand at 4. Moreover, she adds, Baker failed to provide a “record-based

valuation” of punitive damages or the cost of injunctive relief, and attorneys’ fees cannot count

towards the amount in controversy.

at 4–5.

While it is a close call, Baker has failed to satisfy her burden of proving that the amount

in controversy exceeds $75,000. First, as noted above, Baker did not provide any affidavits,

declarations, or other evidence supporting her notice of removal. See Apton,

(“‘[W]hen the plaintiff contests, or the court questions, the defendant’s allegation’ about the

amount in controversy once the case has been so removed, ‘[e]vidence establishing the amount is

required[.]” (second alteration in original) (quoting Dart Cherokee, 574 U.S. at 89)); cf.

Pesticides v. Dr Pepper Snapple Grp., Inc.,

(D.D.C. 2018) (concluding

that the amount in controversy was satisfied based on a sworn declaration submitted by the

defendants).

Second, the complaint itself does not definitively set the amount in controversy. See

Breakman v. AOL LLC,

(D.D.C. 2008) (recognizing a “strong

presumption” that a complaint filed in state court does not allege an amount in controversy

sufficient to confer federal jurisdiction (citation omitted)); Sloan,

, at *6

(noting that Dart Cherokee did not disturb the “strong presumption” articulated in Breakman); St.

Paul Mercury Indem. Co. v. Red Cab Co.,

(1938). The complaint states that

for her claim of tortious interference with contract, Hunt “is entitled to compensatory and

punitive damages in an amount to be determined at trial.” Compl., Count I ¶ 4(h).1 And for her

claim of tortious interference with prospective economic advantage, Hunt claims only that

1 Hunt points out that she does not bring a breach of contract claim against Baker. Rather, the “breach-of-contract claims are the subject of a separate lawsuit against the NBA, which remains pending” in D.C. Superior Court. Pl. Mot. to Remand at 5 (emphasis added).

7 Baker’s wrongful acts “materially contributed to the Sheriff’s Office’s decision” not to hire her

as a contractor. Compl. ¶ 74. While the complaint does suggest some causal relationship

between Baker’s actions and the loss of the two contracts—which is a necessary element of a

tortious interference claim—it is ultimately silent as to the amount of damages she requests. See

Zuckman,

(finding that a complaint was ambiguous because the plaintiff

did not “expressly indicate[]” the full extent of his damages); Ma v. United Rentals (N. Am.),

Inc.,

, 416 (S.D.N.Y. 2023) (“Allegations of injury themselves, without any

statement of damages, . . . do[] not give rise to a finding that the amount in controversy exceeds

$75,000.”)

Third, Hunt has subsequently “clarif[ied] the amount in controversy” in an effort to

resolve the complaint’s ambiguity. Zuckman,

. In addition to her motion

to remand, Hunt simultaneously submitted a “stipulation regarding damages” in which she

“expressly confirms that she has not sought and will not seek damages exceeding $75,000 in this

action.” Pl.’s Stipulation Regarding Damages at 1. The stipulation, which is “intended to be

fully binding upon [Hunt],” states that she “stipulates and agrees that she will not seek, accept, or

enforce any judgment for damages, whether compensatory, punitive, statutory, or otherwise,

whether considered individually or in the aggregate, against [Baker] in excess of $75,000,

exclusive of interest and costs, in this action.”

at 1–2.

“In instances where the complaint is ambiguous, the plaintiff—who is, after all, the

master of [her] complaint—may hence clarify the amount in controversy with affidavits or

stipulations.” Zuckman,

(citing Standard Fire Ins. Co. v. Knowles,

(2013)); see also Apton, 233 F. Supp. 3d at 14–15 (holding that the defendants

failed to prove that the amount in controversy exceeded $75,000 because the plaintiff “declared

8 under penalty of perjury that his compensatory damages and attorneys’ fees are approximately

$13,000” and the defendants offered “no evidence . . . that refutes [the plaintiff’s]

representations”). Hunt’s stipulation clarifies that she will neither seek nor accept nor enforce

any judgment for damages in excess of $75,000. Moreover, the stipulation is binding on her

under the doctrine of judicial estoppel. Zuckman,

(citing Moses v.

Howard Univ. Hosp.,

(D.C. Cir. 2010)); Standard Fire, 568 U.S. at 595–96

(noting that stipulations by parties seeking to avoid removal to federal court must be “legally

binding on all plaintiffs”). In light of the complaint’s ambiguity, Hunt’s subsequent stipulation,

and the absence of any evidence to the contrary, the Court finds that Baker has failed to prove

that the amount in controversy exceeds the jurisdictional minimum. See Apton,

; see also Luce v. Kohl’s Dep’t Stores, Inc.,

(D. Conn. 2014)

(concluding that a post-removal stipulation “suffices to refute any preponderance showing that

[the plaintiff’s] claim amounts to more than $75,000 in damages”); Taylor v. Am. Fam. Mut. Ins.

Co., S.I., No. 21-cv-75,

, at *2 (E.D. Mo. Feb. 19, 2021); Arter v. Pathmark

Stores, Inc., No. 14-cv-6933,

, at *2 (E.D.N.Y. Dec. 31, 2014) (collecting

cases).2

2 Baker does not argue that the punitive damages, injunctive relief, or attorneys’ fees sought by the complaint would exceed $75,000. In any case, stacking those forms of relief on top of compensatory damages would still not raise the amount in controversy above the jurisdictional threshold. See Apton,

(recognizing that “the mere possibility of a punitive damages award is insufficient to prove that the amount in controversy requirement has been met” (citation omitted)); Zuckman,

(noting that “general assertions that the cost of injunctive relief would exceed $75,000 are too speculative to establish diversity jurisdiction”); Griffin v. Coastal Int’l Sec., Inc., No. 06-cv-2246,

, at *3 (D.D.C. June 4, 2007) (“Courts in this District have determined that attorney’s fees do not count towards the amount in controversy requirement unless they ‘are provided for by a contract in issue or by a statute in controversy.’” (citation omitted)); see also Inst. for Truth in Mktg. v. Total Health Network Corp.,

(D.D.C. 2018) (“It is well established that a

9 IV. Conclusion

For the foregoing reasons, the Court will grant Hunt’s motion to remand this matter to the

D.C. Superior Court. A separate Order shall accompany this memorandum opinion.

CHRISTOPHER R. COOPER United States District Judge

Date: October 17, 2025

defendant may not rely on sheer speculation to satisfy its burden of showing the amount in controversy.”).

10