A federal judge just remanded a wage-and-hour case, and used two Simpsons references to do it. That’s enough to embiggen my blogging motivation.

This isn’t just a cromulent decision—it’s a reminder that attorneys’ fees can’t be used to shoehorn a small state wage claim into federal court.

TL;DR: A federal judge in Pennsylvania kicked a wage-and-hour case back to state court after finding that the employer couldn’t show more than $75,000 was at stake. The plaintiff’s actual damages were just $9,350, and the court concluded that attorneys’ fees of $65,650—required to cross the jurisdictional threshold—wouldn’t be “reasonable” under state law. Bonus: the opinion features not one, but two references to The Simpsons.

📄 Read the full opinion here

The Facts: Clocking In, Walking Out—But Not Paid for Either (Which would definitely land you on Mr. Burns’s “do not pay” list)

The plaintiff, a manufacturing employee, claimed that his employer violated the Pennsylvania Minimum Wage Act (PMWA)  by failing to pay him (and others) for time spent walking to and from their job stations at the start and end of their shifts. He filed a putative class action in state court seeking unpaid overtime, interest, costs, and attorneys’ fees.

The company removed the case to federal court, arguing the amount in controversy exceeded $75,000: roughly $9,350 in unpaid wages plus a projected $78,000+ in attorneys’ fees.

The plaintiff moved to remand the case back to the Philadelphia Court of Common Pleas—and the court agreed.

The Legal Breakdown: A “Reasonable” Fee Can’t Do All the Heavy Lifting (This fee theory belongs in the Springfield Historical Society’s basement)

To stay in federal court under diversity jurisdiction, the case must involve (1) parties from different states, and (2) an amount in controversy exceeding $75,000, excluding interest and costs (28 U.S.C. § 1332(a)). Here, the fight was about the second requirement.

The court acknowledged that under the PMWA, prevailing plaintiffs can recover “reasonable” attorneys’ fees (43 P.S. § 333.113). But would a $65,650 fee award on a $9,350 claim be “reasonable”? Not in this universe.

The judge looked to Pennsylvania courts interpreting similar fee-shifting provisions in Unfair Trade Practices and Consumer Protection Law (UTPCPL). While there’s no fixed ratio, state courts have said that even a 2:1 or 3:1 ratio of fees to damages can raise red flags. A 7:1 ratio? Not reasonable, especially given the case’s simplicity, limited discovery, and lack of novel legal questions.

The court also expressed concern about federalism and judicial economy—warning against letting attorneys’ fees become a backdoor to federal jurisdiction in state-law claims.

Three Takeaways for Employers (and Their Lawyers Who Know the Law Better Than Lionel Hutz)

✅ Don’t count on removal just because the statute allows a prevailing plaintiff to recover reasonable attorneys’ fees. If the underlying damages are modest, and the projected legal fees look disproportionate, courts may reject the math.

✅PMWA claims may not belong in federal court. Even if a claim includes fees, Pennsylvania’s interpretation of “reasonable” may stop the case from clearing the $75K bar—and if the defendant is a resident of the forum state, removal based on diversity jurisdiction is barred altogether (28 U.S.C. § 1441(b)(2)).

✅ This is a reminder to analyze jurisdictional strategy early. If you’re trying to remove a borderline case, consider how courts might evaluate the proportionality of fees to damages—especially under Pennsylvania law.

Final Thought (This claim had about as much chance in federal court as Ralph Wiggum on Law Review)

If you’re gonna cite The Simpsons in a judicial opinion—twice—you’d better stick the landing. The court did just that, holding that “embiggening” the amount in controversy with sky-high legal fees wasn’t “perfectly cromulent.”

This wasn’t a grandiose legal drama—it was more of a Lard Lad-sized misunderstanding of fee reasonableness. D’oh! When your damages are under $10K and your removal strategy leans almost entirely on projected legal fees, don’t expect a federal court to say “Excellent.”