Barboza v. FCA US LLC

CourtDistrict Court, E.D. California
DecidedFebruary 19, 2025
Docket2:24-cv-02314
StatusUnknown

This text of Barboza v. FCA US LLC (Barboza v. FCA US LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barboza v. FCA US LLC, (E.D. Cal. 2025).

Opinion

8 UNITED STATES DISTRICT COURT

9 FOR THE EASTERN DISTRICT OF CALIFORNIA

11 EDUARDO BARBOZA, et al., No. 2:23-cv-02314-DJC-JDP

12 Plaintiffs, v. 13 ORDER FCA US, LLC, 14 Defendant. 15 16

17 Plaintiffs Eduardo Barboza and Joanna Castellano have filed the present action

18 against Defendant FCA US, LLC based on allegations that Defendant knowingly sold

19 Plaintiffs a vehicle with a transmission that contained one or more defects. After this

20 suit was originally filed in the San Joaquin County Superior Court, Defendant removed

21 it to this court on the basis of diversity jurisdiction. Plaintiffs now seek to have the

22 action remanded to the state court and Defendant asks that the Court dismiss 23 Plaintiffs’ Complaint for failure to state a claim. 24 For the reasons stated below, Plaintiffs’ Motion to Remand (Mot. (ECF No. 18)) 25 is granted and Defendant’s Motion to Dismiss (ECF No. 6) is denied as moot. 26 I. Background 27 Plaintiffs allegedly entered into a warranty contract with Defendant for a 2016 28 Chrysler 200 vehicle. Plaintiffs claim that Defendant failed to service or repair defects 1 in the vehicle, most specifically a “transmission defect,” despite the presence of

2 express and implied warranties. Plaintiffs bring causes of action for violations of Civil

3 Code sections 1793.2(a)(3), (b), and (d) as well as causes of action for fraudulent

4 inducement and violation of the implied warranty. (Compl. (ECF No. 1-2, Ex. A) at 8–

5 13.) Plaintiffs allege that as a result of Defendant’s actions “Plaintiffs suffered damages

6 in a sum to be proven at trial in an amount that is not less than $35,001.00.” (Id. ¶ 33.)

7 Plaintiffs originally filed suit in San Joaquin County Superior Court but

8 Defendant removed this action to federal court on the basis of diversity jurisdiction.

9 (See Not. of Removal (ECF No. 1.).) Plaintiffs now move for the Court to remand this

10 action on the grounds that Defendant has not shown that the amount in controversy

11 requirement for diversity jurisdiction is satisfied. (See Mot.) Defendant separately

12 moves to dismiss Plaintiff’s Complaint for failure to state a claim. The Court must first

13 address whether removal was proper and if it has subject matter jurisdiction over this

14 action.

15 II. Legal Standard

16 A case may be removed to federal court if that court would have original

17 jurisdiction over the matter, which generally requires asserting federal question

18 jurisdiction under 28 U.S.C. § 1331 or diversity jurisdiction under 28 U.S.C. § 1332.

19 See 28 U.S.C. § 1441; Hunter v. Philip Morris USA, 582 F.3d 1039, 1042 (9th Cir. 2009)

20 (quoting Ansley v. Ameriquest Mortg. Co., 340 F.3d 858, 861 (9th Cir. 2003) (citation

21 omitted)). “However, it is to be presumed that a cause lies outside the limited

22 jurisdiction of the federal courts and the burden of establishing the contrary rests

23 upon the party asserting jurisdiction.” Hunter, 582 F.3d at 1042 (quoting Abrego

24 Abrego v. The Dow Chem. Co., 443 F.3d 676, 684 (9th Cir. 2006) (citation omitted))

25 (internal quotation marks and alterations omitted). As a result, “[t]he ‘strong

26 presumption against removal jurisdiction means that the defendant always has the

27 burden of establishing that removal is proper,’ and that the court resolves all

28 ambiguity in favor of remand to state court.” Id. (quoting Gaus v. Miles, Inc., 980 F.2d 1 564, 566 (9th Cir. 1992) (per curiam) (internal quotation marks omitted)).

2 In order for the Court to have subject matter jurisdiction under 28 U.S.C.

3 § 1332, there must be complete diversity of citizenship of the parties and the amount

4 in controversy must exceed $75,000. Where removal on the basis of diversity is

5 challenged, the proponent of federal jurisdiction must establish by preponderance of

6 the evidence that the amount in controversy exceeds $75,000. Sanchez v.

7 Monumental Life Ins., 102 F.3d 398, 404 (9th Cir. 1996).

8 III. Discussion

9 In removing this action, Defendant calculated the amount in controversy in two

10 main steps. First, Defendant asserted Plaintiffs’ complaint sought actual damages of

11 $30,581.98 in restitution by taking the price of the vehicle as stated in the Retail Sales

12 Installment Contract (see ECF No. 1-2, Ex. E), adding the amount paid in finance

13 charges, and subtracting the price of the optional service contract and a milage

14 deduction as a “reasonable allowance” for use of the vehicle. (Not. of Removal ¶ 20.)

15 Defendant then added two times the amount of actual damages in civil penalties

16 based on Plaintiffs’ claim that they were entitled to civil penalties under the Song-

17 Beverly Warranty Act. (Id. at 21.) Based on this, Defendant argued that Plaintiffs’

18 complaint asserted an amount in controversy of $91,745.94. (Id.) Defendant also

19 contended that the amount in controversy is satisfied on the face of the complaint and

20 that the attorney’s fees requested by Plaintiffs would bring this case within the

21 $75,000.00 amount in controversy.

22 Plaintiffs’ Motion contests whether removal was proper under diversity

23 jurisdiction based on a failure to satisfy the amount in controversy requirement.1 Most

24 relevant are Plaintiffs’ factual attacks on Defendant’s calculation of actual damages

25 and attorney’s fees as well as Plaintiffs’ challenge to Defendant’s statement that

26 diversity is satisfied on the face of Plaintiffs’ Complaint.

28 1 Plaintiffs do not contest the parties’ diversity, only the amount in controversy. 1 A. Actual Damages

2 Plaintiffs first contend that Defendant improperly calculated actual damages by

3 using the total price of the vehicle from the Retail Sales Installment Contract to

4 calculate Plaintiffs’ actual damages. Plaintiffs argue Defendant failed to present

5 “essential facts about the purchase price” including whether Plaintiff made all interest

6 payments on the vehicle. (Mot. at 7.) Because section 1793.2 permits recovery based

7 on “the actual price paid” by a purchaser, other courts have rejected calculations of

8 actual damages based on the total cost of the vehicle where the vehicle was financed,

9 and the defendant failed to establish by a preponderance of the evidence that all

10 payments had been made and finance charges paid. See Savall v. FCA US LLC, No.

11 21-cv-00195-JM-KSC, 2021 WL 1661051, at *2 (S.D. Cal. Apr. 28, 2021).

12 Defendant argues that this would “transfer an unreasonable and impossible

13 burden on Defendant” to determine whether Plaintiff had made all payments within

14 the time for removal. (Opp’n (ECF No. 21) at 6.) But on removal, it is Defendant’s

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Barboza v. FCA US LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barboza-v-fca-us-llc-caed-2025.