Chase v. Kia Motors America, Inc.

CourtDistrict Court, N.D. California
DecidedFebruary 24, 2023
Docket3:22-cv-09082
StatusUnknown

This text of Chase v. Kia Motors America, Inc. (Chase v. Kia Motors America, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chase v. Kia Motors America, Inc., (N.D. Cal. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 JOHN CHASE, et al., Case No. 22-cv-09082-JCS

8 Plaintiffs, ORDER REMANDING SUA SPONTE 9 v. FOR LACK OF JURISDICTION

10 KIA MOTORS AMERICA, INC., et al., Defendants. 11

12 I. INTRODUCTION 13 Defendant Hyundai Capital America d/b/a Kia Finance (“Kia Finance”) removed this case 14 from the California Superior Court for the County of Alameda,1 asserting that a federal claim that 15 Plaintiffs added in arbitration while state court proceedings were stayed rendered the case 16 removable once the stay was vacated. Plaintiffs John Chase and Hillary Chase move to remand on 17 the basis that Kia Finance’s removal was untimely, arguing that Kia Finance should have removed 18 when Plaintiffs first raised their federal claim in arbitration. Defendants Kia Motors America, Inc. 19 (“Kia Motors”) and Michael C. Stead, Inc. d/b/a Michael Stead’s Hilltop Ford Kia (“Hilltop”) join 20 Kia Finance in opposing remand. 21 The Court held a hearing on February 24, 2023. Contrary to all parties’ positions, the 22 federal claim never became part of the case before the Superior Court, and thus is not part of the 23 case before this Court. This Court therefore lacks subject matter jurisdiction and REMANDS the 24 case sua sponte on that basis. Lacking jurisdiction, the Court does not reach the procedural 25 arguments asserted by the parties.2 26

27 1 In state court, this case was assigned case number RG19010993. 1 II. BACKGROUND 2 A. Procedural History 3 This case began with automotive defect and warranty claims under California law that 4 Plaintiffs filed in the Alameda County Superior Court. On August 16, 2019, the parties filed a 5 stipulation in the state court action to stay proceedings pending arbitration. After acknowledging 6 that Defendants had demanded that Plaintiffs submit their claims to arbitration, the relevant 7 portion of the stipulation reads as follows:

8 The Parties hereby stipulate and agree as follows:

9 1. The dispute between the Parties as described in the complaint shall be submitted to arbitration at JAMS so that each of Plaintiffs’ causes 10 of action against Defendants may be fully resolved via binding arbitration. 11 2. All proceedings in this matter, including current discovery 12 deadlines, shall be stayed pending the completion of arbitration, save for Case Management Conferences or other status conferences set by 13 the Court in its discretion to monitor the status of arbitration. The Parties respectfully suggest that such a status conference be set 14 approximately one year from now to permit time to conduct the arbitration and a receive a final, binding award. . . . . 15 16 Notice of Removal (dkt. 1) Ex. A at 96. 17 On August 20, 2019, the Superior Court signed and entered the parties’ proposed order, 18 which states that the “Court accepts the above stipulation of the parties to submit this matter to 19 binding arbitration,” “[t]he matter is STAYED pending the completion of arbitration,” and a status 20 conference would occur the following year “to monitor the status of arbitration.” Id. at 104. The 21 parties then proceeded with arbitration. 22 In September of 2020, Plaintiffs requested and obtained leave from the arbitrator to add 23 claims by John Chase under the Fair Credit Reporting Act (“FCRA”)—a federal law—and its 24 California analogue against Kia Finance, and filed an addendum to their arbitration demand 25 asserting those additional claims. Conn Decl. (dkt. 10-1) ¶¶ 2–4 & Exs. A, B; Notice of Removal 26 Ex. B at 58–60. Kia Finance filed a dispositive motion as to the new claims, but the arbitrator 27 denied that motion and allowed those claims to proceed. Conn Decl. ¶¶ 8–9 & Exs. D, E. 1 arbitration was pending. In three such statements filed in January through October of 2022, Kia 2 Finance noted that “Plaintiffs allege . . . FCRA claims,” and also that “[t]his case is currently in 3 arbitration with the Evidentiary [sic] hearing anticipated to occur in 2022.” Conn Decl. Ex. G at 2, 4 Ex. H at 2, Ex. I at 2. 5 On September 12, 2022, Plaintiffs moved in the Superior Court to vacate the order staying 6 the case pending arbitration and to lift the stay under section 1281.98 of the California Code of 7 Civil Procedure, arguing that Kia Finance had failed to pay an arbitration fee when required. 8 Notice of Removal Ex. A at 320–25. That statute provides in relevant part:

9 (a) (1) In an employment or consumer arbitration that requires . . . 10 that the drafting party pay certain fees and costs during the pendency of an arbitration proceeding, if the fees or costs required to continue 11 the arbitration proceeding are not paid within 30 days after the due date, the drafting party is in material breach of the arbitration 12 agreement, is in default of the arbitration, and waives its right to compel the employee or consumer to proceed with that arbitration as 13 a result of the material breach.

14 [. . .]

15 (b) If the drafting party materially breaches the arbitration agreement and is in default under subdivision (a), the employee or consumer may 16 unilaterally elect to do any of the following:

17 (1) Withdraw the claim from arbitration and proceed in a court of appropriate jurisdiction. If the employee or consumer withdraws 18 the claim from arbitration and proceeds with an action in a court of appropriate jurisdiction, the statute of limitations with regard to all 19 claims brought or that relate back to any claim brought in arbitration shall be tolled as of the date of the first filing of a claim in any court, 20 arbitration forum, or other dispute resolution forum.

21 [. . .] 22 Cal. Civ. Proc. Code § 1281.98. 23 Plaintiffs’ motion “request[ed] that the Court: (a) enter an order vacating the Court’s 24 August 20, 2019 Order staying this case pending the completion of arbitration; and (b) permit 25 Plaintiffs to proceed in this action in the Alameda County Superior Court under Plaintiffs’ original 26 Complaint,” and indicated in a footnote that “[u]pon the Court vacating the August 20, 2019 27 Order, Plaintiffs will seek leave to file a First Amended Complaint to allege additional causes of 1 A at 321 & n.1. That motion did not specifically reference Plaintiffs’ claim under the FCRA. 2 Defendants argued that section 1281.98 did not apply to the facts at hand and that it was 3 preempted by the Federal Arbitration Act (“FAA”), among other reasons to deny the motion, but 4 in an order dated December 6, 2022, the Superior Court rejected those arguments and granted 5 Plaintiffs’ motion. See Notice of Removal Ex. A at 609–15.3 Since the merits of that decision are 6 not before this Court, this order does not recount the details of Defendants’ arguments or the 7 Superior Court’s reasoning. The Superior Court’s order did not address Plaintiffs’ FCRA claim or 8 other claims added in arbitration, but merely stated that Plaintiffs’ motion was granted and that the 9 stay was vacated, and set a case management conference for May 9, 2023. Id. at 609. Plaintiffs 10 never filed an amended complaint in the Superior Court. Conn Decl. ¶ 7. 11 Kia Finance removed to this Court on December 22, 2022, asserting federal question 12 jurisdiction based on Plaintiffs’ FCRA claim, and contending that removal was timely because 13 “[w]hen the State Court ordered the matter from arbitration back to State Court on December 6, 14 2022 and lifted the stay, this was the first time that the operative complaint in State Court included 15 a federal cause of action.” See Notice of Removal ¶¶ 9, 16. 16 B.

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Chase v. Kia Motors America, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/chase-v-kia-motors-america-inc-cand-2023.