Allen v. Amazon.com Services LLC

CourtDistrict Court, W.D. Washington
DecidedAugust 2, 2024
Docket2:24-cv-00195
StatusUnknown

This text of Allen v. Amazon.com Services LLC (Allen v. Amazon.com Services LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Allen v. Amazon.com Services LLC, (W.D. Wash. 2024).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 CALEB ALLEN and KASEY ALLEN, CASE NO. 2:24-cv-00195-LK 11 individuals, and as plaintiff's father and mother and with father as guardian on behalf ORDER DENYING UNOPPOSED 12 of minor child, A.A., MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT 13 Plaintiffs, AND FOR JOINDER OF v. SHENZHEN CHEYANG 14 TECHNOLOGY CO. AS A AMAZON.COM SERVICES, LLC, DEFENDANT 15 Defendant. 16 17 This matter comes before the Court on Plaintiffs’ Unopposed Motion for Leave to File First 18 Amended Complaint and Joinder of Shenzhen Cheyang Technology Co., Ltd. as a Defendant. Dkt. 19 No. 19. For the following reasons, the Court denies Plaintiffs’ motion. 20 I. BACKGROUND 21 On February 12, 2024, Plaintiffs filed a complaint against Defendant Amazon.com 22 Services LLC (“Amazon”), asserting claims of products liability, strict products liability, breach 23 of implied warranties, negligent undertaking, and infliction of emotional distress. Dkt. No. 1 at 8– 24 1 17. Plaintiffs’ claims arise from Plaintiff A.A.’s alleged ingestion of a battery that purportedly fell 2 out of a wireless remote control mounted on the steering wheel of Plaintiffs’ vehicle, which was 3 purchased from a previous owner. Id. at 2. At the time they filed their complaint, Plaintiffs had not 4 yet identified the specific product in question, but alleged that the remote control was sold under

5 a brand promoted by Amazon. Id. 6 Plaintiffs represent that they have since received discovery from the previous owner of 7 Plaintiffs’ vehicle, id., which led to the identification of the remote control as a “Podofo Double 8 Din Car Stereo with Apple Carplay Android Auto, 7 Inch Touch Screen Bluetooth Radio Car 9 Audio with Backup Camera, Voice Control, FM Radio, Mirror Link, USB Playback & Charging,” 10 Dkt. No. 19 at 3; see also Dkt. No. 19-3 at 3. Plaintiffs aver that this product is associated with 11 Shenzhen Cheyang Technology, Co., Ltd. (“SCT”), who they believe is the manufacturer and/or 12 supplier of the remote control and consequently “may have knowledge related to the manufacture 13 and design of the Defective Product.” Dkt. No. 19 at 3; see also Dkt. No. 19-3 at 3 (Amazon page 14 of remote control listing SCT as seller).

15 II. DISCUSSION 16 A. Legal Standards 17 1. Amendment 18 Under Rule 15 of the Federal Rules of Civil Procedure, a “court should freely give leave” 19 to amend a pleading “when justice so requires.” Fed. R. Civ. P. 15(a)(2). “[T]his policy is to be 20 applied with extreme liberality.” Owens v. Kaiser Found. Health Plan, Inc., 244 F.3d 708, 712 21 (9th Cir. 2001) (quoting Morongo Band of Mission Indians v. Rose, 893 F.2d 1074, 1079 (9th Cir. 22 1990)). Courts may deny a motion for leave to amend “if there is strong evidence of ‘undue delay, 23 bad faith or dilatory motive on the part of the movant, repeated failure to cure deficiencies by

24 amendments previously allowed, undue prejudice to the opposing party by virtue of allowance of 1 the amendment, [or] futility of amendment, etc.’” Sonoma Cnty. Ass’n of Retired Emps. v. Sonoma 2 Cnty., 708 F.3d 1109, 1117 (9th Cir. 2013) (quoting Foman v. Davis, 371 U.S. 178, 182 (1962)). 3 Furthermore, “the consideration of prejudice to the opposing party . . . carries the greatest weight.” 4 Eminence Cap., LLC v. Aspeon, Inc., 316 F.3d 1048, 1052 (9th Cir. 2013) (per curiam). “Absent

5 prejudice, or a strong showing of any of the remaining Foman factors, there exists a presumption 6 under Rule 15(a) in favor of granting leave to amend.” Id. 7 2. Joinder 8 Under Rule 20 of the Federal Rules of Civil Procedure, a party may be permissively joined 9 as a defendant in an action if “(A) any right to relief is asserted against them jointly, severally, or 10 in the alternative with respect to or arising out of the same transaction, occurrence, or series of 11 transactions or occurrences; and (B) any question of law or fact common to all defendants will 12 arise in the action.” Fed. R. Civ. P. 20(a)(2); see also POW Nev., LLC v. Doe 2, No. C17-1649- 13 RSM, 2018 WL 525958, at *1 (W.D. Wash. Jan. 24, 2018). Joinder must “comport with the 14 principles of fundamental fairness” and must not prejudice either side. Coleman v. Quaker Oats

15 Co., 232 F.3d 1271, 1296 (9th Cir. 2000) (quoting Desert Empire Bank v. Ins. Co. of N. Am., 623 16 F.2d 1371, 1375 (9th Cir. 1980)). 17 Rule 20 is “construed liberally in order to promote trial convenience and to expedite the 18 final determination of disputes, thereby preventing multiple lawsuits.” League to Save Lake Tahoe 19 v. Tahoe Reg’l Plan. Agency, 558 F.2d 914, 917 (9th Cir. 1977); see also United Mine Workers v. 20 Gibbs, 383 U.S. 715, 724 (1966) (“Under the Rules, the impulse is toward entertaining the broadest 21 possible scope of action consistent with fairness to the parties; joinder of claims, parties and 22 remedies is strongly encouraged.”). The same-transaction and common-question requirements are 23 “not rigid tests, but rather are flexible concepts used by the courts to implement the purpose of

24 Rule 20 and therefore are to be read as broadly as possible whenever doing so is likely to promote 1 judicial economy.” Almont Ambulatory Surgery Ctr., LLC v. UnitedHealth Grp., Inc., 99 F. Supp. 2 3d 1110, 1187–88 (C.D. Cal. 2015) (cleaned up). 3 B. Plaintiffs’ Motion is Denied 4 After considering the relevant factors, the Court finds that leave to amend should be denied.

5 Plaintiffs’ proposed amended complaint does not adequately plead the parties’ citizenship, and the 6 proposed complaint therefore fails to establish subject matter jurisdiction. 7 “Absent unusual circumstances, a party seeking to invoke diversity jurisdiction should be 8 able to allege affirmatively the actual citizenship of the relevant parties.” Kanter v. Warner- 9 Lambert Co., 265 F.3d 853, 857 (9th Cir. 2001); Dodo Int’l, Inc. v. Parker, No. C20-1116-JCC, 10 2020 WL 12834160, at *1 (W.D. Wash. Dec. 30, 2020).1 Plaintiffs’ proposed amended complaint, 11 however, does not allege enough facts to establish any party’s citizenship. Plaintiffs allege that 12 SCT “is a limited company formed and existing under the laws of the People[’]s Republic of China, 13 with a business address at B308, Block B, Donghaiwang Industrial Zone, No. 369 Bulong Road, 14 Bantian Street Longgang, Dist. Shenzhen, China 518129.” Dkt. No. 19-1 at 5. If a “limited

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Allen v. Amazon.com Services LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/allen-v-amazoncom-services-llc-wawd-2024.