Anderson v. Nissan Motor Acceptance Corp.

326 F. Supp. 2d 760, 2003 U.S. Dist. LEXIS 25584, 2003 WL 23678386
CourtDistrict Court, S.D. Mississippi
DecidedAugust 22, 2003
DocketCIV.A. 3:03CV6LN
StatusPublished
Cited by2 cases

This text of 326 F. Supp. 2d 760 (Anderson v. Nissan Motor Acceptance Corp.) is published on Counsel Stack Legal Research, covering District Court, S.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson v. Nissan Motor Acceptance Corp., 326 F. Supp. 2d 760, 2003 U.S. Dist. LEXIS 25584, 2003 WL 23678386 (S.D. Miss. 2003).

Opinion

MEMORANDUM OPINION AND ORDER

TOM S. LEE, District Judge.

This cause is before the court on the motion of plaintiffs to remand pursuant to 28 U.S.C. § 1447. Defendant Nissan Motor Acceptance Corporation (NMAC) has responded in opposition to the motion and has filed an alternative motion to certify order for appeal under 28 U.S.C. § 1292(b). The court, having considered the memoranda of authorities, together with attachments, submitted by the parties, concludes that plaintiffs’ motion to remand should be granted, and further concludes that NMAC’s motion for certification for interlocutory appeal should be denied.

The eighty-four plaintiffs in this cause filed suit in the Circuit Court of Hinds County, Mississippi against NMAC and approximately thirty Mississippi Nissan dealers alleging claims and seeking damages for defendants’ alleged suppression of material facts, deceit/fraudulent concealment, negligent or reckless misrepresentation, conspiracy, breach of the duty of good faith and fair dealing, breach of fiduciary duty, unjust enrichment and negligent and/or wanton training and supervision relative to plaintiffs’ financing of their automobile purchases from the defendant dealers. Plaintiffs complain, in particular, that the dealer defendants, in combination and conspiracy with NMAC, engaged in a fraudulent and secret scheme to deceive plaintiffs into financing their automobile purchases at inflated rates through NMAC’s retail financing program. According to the complaint, NMAC periodically established a schedule of approved rates at which automobile purchases could be financed, the approved rates being established in tiers, based on the applicant’s creditworthiness. 1 These rates represented the lowest rates at which NMAC would finance a purchase. Plaintiffs allege, however, that NMAC “trained, allowed, induced, encouraged and conspired with Defendant Dealers to charge rates greater than the approved rates,” i.e., to mark up the rates, and in the case of each plaintiff, the defendant dealers (and NMAC) induced plaintiffs to pay a higher rate of interest than NMAC’s approved and required rate by misrepresenting to plaintiffs, including by misleading documentation, actions and statements, that the higher rate presented to them was, in fact, NMAC’s approved or required rate. Plaintiffs also allege that in the cases of those plaintiffs who are African-American, the defendants further deceived and conspired to defraud them by charging them an even higher mark-up than that charged to similarly situated white applicants, without disclosing that they were being charged a higher rate than the white applicants. Plaintiffs allege that NMAC effected this finance charge mark-up system by agreeing that dealers who were able to *763 induce a customer to enter into a loan at a higher interest rate than the approved rate would be paid a portion of the markup.

NMAC promptly removed the case on the dual bases of federal question jurisdiction under 28 U.S.C. § 1831 and bankruptcy removal jurisdiction under 28 U.S.C. § 1452. As to the former, NMAC asserted that federal question jurisdiction exists under the Equal Credit Opportunity Act, 15 U.S.C. § 1691 et seg., and the Civil Rights Act, 42 U.S.C. §§ 1981 and 1982, since the basis of plaintiffs’ lawsuit is alleged race discrimination. NMAC contended that bankruptcy jurisdiction also exists pursuant to 28 U.S.C. § 1334 because one or more of the plaintiffs (perhaps as many as nineteen) had at one time or another subsequent to their loan transactions filed a voluntary petition for bankruptcy under the United States Bankruptcy Code and because this lawsuit is therefore property of these plaintiffs’ bankruptcy estates which is due to be heard and resolved exclusively by the bankruptcy court.

Federal Question Jurisdiction:

Under 28 U.S.C. § 1441, “any civil action brought in a State court of which the district courts of the United States have original jurisdiction, may be removed by the defendant ... to the district court of the United States for the district and division embracing the place where such action is pending.” 28 U.S.C. § 1441(a). Thus, for the district court to have removal jurisdiction, 28 U.S.C. § 1441(a) requires that the case be one over “which the district courts of the United States have original jurisdiction.” District courts have original jurisdiction over cases concerning a “federal question,” that is, cases “arising under the Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331.

The determination whether a plaintiffs claim arises under federal law is made by examining the “well pleaded” allegations of the complaint, ignoring potential defenses. Under this “well pleaded complaint” rule, “ ‘a suit arises under the Constitution and laws of the United States only when the plaintiffs statement of his own cause of action shows that it is based upon those laws or that Constitution....’” Beneficial Nat’l Bank v. Anderson, 539 U.S. 1, 123 S.Ct. 2058, 2062, 156 L.Ed.2d 1 (2003) (citations omitted). Thus, “[a]s a general rule, absent diversity jurisdiction, a case will not be removable if the complaint does not affirmatively allege a federal claim.” Id.See also Heimann v. National Elevator Indus. Pension Fund, 187 F.3d 493, 499 (5th Cir.1999) (“It is well-settled that a cause of action arises under federal law only when the plaintiffs well-pleaded complaint raises issues of federal law.”).

Because the well-pleaded complaint rule provides that jurisdiction will be determined based solely on the plaintiffs complaint, “the rule makes the plaintiff master of the claim, and federal jurisdiction may be avoided by exclusive reliance on state law.... Accordingly, even if both federal and state law provide a remedy, the plaintiff can avoid federal jurisdiction by pleading solely state law claims—at the price, of course, of foregoing the federal remedies.” Credit Acceptance Corp. v. Addison, 2000 WL 33324363, *2 (N.D.Miss.2000) (citations omitted). See also Avitts v. Amoco Prod. Co.,

Related

Abraham v. Smith
550 B.R. 314 (N.D. Mississippi, 2016)
Garner v. BANKPLUS
470 B.R. 402 (S.D. Mississippi, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
326 F. Supp. 2d 760, 2003 U.S. Dist. LEXIS 25584, 2003 WL 23678386, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-nissan-motor-acceptance-corp-mssd-2003.