Cesar Tomas Avalos v. General Motors LLC

District Court, C.D. California·Decided May 6, 2026·No. 2:25-cv-11434·Unknown

Opinion

CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION CESAR TOMAS AVALOS, CASE NO. CV 25-11434-AS Plaintiff, v. ORDER DENYING PLAINTIFF’S Defendant. On August 5, 2025, Plaintiff Cesar Tomas Avalos (“Plaintiff”), filed a Complaint against Defendant General Motors LLC (“Defendant”), in Los Angeles County Superior Court, Case No. 25STCV23049, asserting claims under the California Song-Beverly Consumer Warranty Act for breach of express warranty, breach of the implied warranty of merchantability, and violation of California Civil Code section 1793.2. (Dkt. No. 1-1, at 10-16 (“Complaint”)). On August 6, 2025, Plaintiff served the Summons and Complaint on Defendant. (Dkt. No. 7-1, at 5-6). On September 4, 2025, Defendant filed an Answer to the Complaint. (Dkt. No. 1- 2). On December 1, 2025, Defendant filed the Notice of Removal, removing the case to this Court based on diversity jurisdiction. (Dkt. No. 1). On December 30, 2025, Plaintiff filed a Motion to Remand (“Motion”) along with a supporting Memorandum of Points and Authorities (“Motion Mem.”), a declaration of counsel (“Plata Decl.”) and an exhibit. (Dkt. No. 7). Plaintiff contends that remand is warranted because Defendant’s removal of the case to this Court (1) was untimely and (2) fails to establish that the case satisfies the amount-in-controversy requirement. (See Motion Mem. at 5-10). On January 6, 2026, Defendant filed an Opposition to the Motion, along with a supporting declaration of counsel (“Fitch Decl.”) and exhibits. (Dkt. No. 12). Plaintiff followed with a Reply on January 22, 2026. (Dkt. No. 13). For the reasons set forth below, the Motion is DENIED.1 Removal of a case from state court to federal court is governed by 28 U.S.C. § 1441, which provides in relevant part that “any civil action brought in a State court of which the district courts of the United States have original jurisdiction, may be removed . . . to the district court of the United States for the

1 The parties consented to the jurisdiction of a United States Magistrate Judge for all purposes. (See Dkt. Nos. 5-6). district and division embracing the place where such action is pending.” 28 U.S.C. § 1441(a). Federal courts have original subject matter jurisdiction where an action presents either a federal question under 28 U.S.C. § 1331 or diversity of citizenship under 28 U.S.C. § 1332. Generally, a court has diversity jurisdiction only when there is complete diversity of citizenship among adverse parties and the amount in controversy exceeds $75,000. See 28 U.S.C. § 1332(a). Remand to state court may be ordered for lack of subject matter jurisdiction or any defect in the removal procedure. See 28 U.S.C. § 1447(c). To protect the jurisdiction of state courts, removal jurisdiction is strictly construed in favor of remand. See Harris v. Bankers Life & Cas. Co., 425 F.3d 689, 698 (9th Cir. 2005); see also Abrego Abrego v. Dow Chem. Co., 443 F.3d 676, 684 (9th Cir. 2006) (“It is to be presumed that a cause lies outside the limited jurisdiction of the federal courts and the burden of establishing the contrary rests upon the party asserting jurisdiction.” (internal quotation marks and brackets omitted)). If there is any doubt as to whether removal is proper, remand must be ordered. Ethridge v. Harbor House Rest., 861 F.2d 1389, 1393 (9th Cir. 1988). “The party seeking removal bears the burden of establishing federal jurisdiction.” Id. As indicated above, Plaintiff’s Motion contends that remand is warranted because Defendant’s removal (1) was untimely and (2) fails to satisfy the amount-in-controversy requirement. (See Motion Memo at 4-10). The Motion is denied. A. Defendant’s Removal Was Timely 1. Applicable Law The Ninth Circuit has explained that there are three pathways for removal of an action from state court based on diversity jurisdiction. See Roth v. CHA Hollywood Med. Ctr., L.P., 720 F.3d 1121, 1124 (9th Cir. 2013). The first two pathways are contained in 28 U.S.C. § 1446(b) and impose thirty-day deadlines for removal. See Dietrich v. Boeing Co., 14 F.4th 1089, 1093 (9th Cir. 2021). The third pathway is based on reading 28 U.S.C. § 1446 together with 28 U.S.C. § 1441 and permits removal up to one year from the filing of the complaint, but this pathway only applies if the first two do not. See Roth, 720 F.3d at 1125-26. The first pathway is set forth by § 1446(b)(1) and states that “[t]he notice of removal of a civil action or proceeding shall be filed within 30 days after the receipt by the defendant, through service or otherwise, of a copy of the initial pleading setting forth the claim for relief upon which such action or proceeding is based, or within 30 days after the service of summons upon the defendant if such initial pleading has then been filed in court and is not required to be served on the defendant, whichever period is shorter.” 28 U.S.C. § 1446(b)(1). Section 1446(b)(1) “only applies if the case stated by the initial pleading is removable on its face,” as determined “through examination of the four corners of the applicable pleadings, not through subjective knowledge or a duty to make further inquiry.” Harris, 425 F.3d at 694. The second pathway is set forth by § 1446(b)(3) and states in relevant part that “if the case stated by the initial pleading is not removable, a notice of removal may be filed within 30 days after receipt by the defendant, through service or otherwise, of a copy of an amended pleading, motion, order or other paper from which it may first be ascertained that the case is one which is or has become removable.” 28 U.S.C. § 1446(b)(3). Section 1446(b)(3) is triggered only where “an amended pleading, motion, order, or other paper . . . [makes] a ground for removal unequivocally clear and certain.” Dietrich, 14 F.4th at 1095. The third pathway is based on the interaction of § 1446 with § 1441. See Roth, 720 F.3d at 1125. Section 1441(a) states that “[e]xcept as otherwise expressly provided by Act of Congress, 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 or the defendants, 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). The Ninth Circuit has explained “that §§ 1441 and 1446, read together, permit a defendant to remove outside the two thirty-day periods on the basis of its own information, provided

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