Colbert Jr. v. General Motors LLC

CourtDistrict Court, E.D. California
DecidedFebruary 7, 2025
Docket1:23-cv-01269
StatusUnknown

This text of Colbert Jr. v. General Motors LLC (Colbert Jr. v. General Motors 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
Colbert Jr. v. General Motors LLC, (E.D. Cal. 2025).

Opinion

6 7 8 9 10 11 UNITED STATES DISTRICT COURT 12 EASTERN DISTRICT OF CALIFORNIA 13 14 BRENT COLBERT, JR., No. 1:23-CV-01269-KES-CDB 15 Plaintiff, ORDER DENYING MOTION TO REMAND 16 v. Doc. 14 17 GENERAL MOTORS, LLC, a limited liability company; and DOES 1 through 10, 18 inclusive, 19 Defendant. 20 21 Plaintiff Brent Colbert Jr. (“Colbert”) moves to remand this action to Kern County 22 Superior Court. Doc. 14 (“MTR”). Defendant General Motors LLC and DOES 1 through 10, 23 inclusive (“GM”), filed an opposition. Doc. 16 (“Opp’n”). Colbert filed a reply. Doc. 18 24 (“Reply”). The Court took the motion under submission. Doc. 15. For the reasons set forth 25 below, Colbert’s motion is denied. 26 I. Background 27 On October 3, 2023, Colbert brought this case in Kern County Superior Court alleging 28 that GM violated various express and implied warranties in their sale of a 2018 Cadillac CT6 to 1 Colbert. Doc. 1-1 (“Compl.”). Colbert alleges that following the purchase of the Cadillac, the car 2 exhibited various defects and malfunctions. Id. ¶ 13. GM attempted to repair the car, and despite 3 their representations that they were successful, the car continued to exhibit issues. Id. ¶¶ 14–15. 4 The complaint asserts three causes of action under the Song-Beverly Consumer Warranty Act 5 (“Song-Beverly Act”) and a fourth cause of action alleging violations of California Business & 6 Professions Code 17200. Id. at 2. Colbert seeks rescission of the purchase contract and 7 restitution, civil penalties in the amount of two times plaintiff’s actual damages, and attorneys’ 8 fees, among other relief. See id. at 14. 9 GM removed the action to this Court on August 23, 2023, based on diversity jurisdiction. 10 Doc. 1 (“Notice of Removal”). In their notice of removal, GM asserted that this Court has subject 11 matter jurisdiction under 28 U.S.C. § 1332(a) because the amount in controversy exceeds $75,000 12 and the parties are completely diverse. Id. at 3–6. Colbert moves to remand the action to Kern 13 County Superior Court, arguing that GM’s notice of removal failed to establish this Court’s 14 jurisdiction. MTR at 6. 15 II. Legal Standard 16 A. Removal Jurisdiction 17 A suit filed in state court may be removed to federal court if the federal court would have 18 had original jurisdiction over the suit. 28 U.S.C. § 1441(a). Removal is proper when a case 19 originally filed in state court presents a federal question or where there is diversity of citizenship 20 among the parties and the amount in controversy exceeds $75,000. See 28 U.S.C. §§ 1331, 21 1332(a). 22 “If at any time before final judgment it appears that the district court lacks subject matter 23 jurisdiction, the case shall be remanded.” 28 U.S.C. § 1447(c). Section 1447(c) “is strictly 24 construed against removal jurisdiction, and the burden of establishing federal jurisdiction falls to 25 the party invoking the statute.” Acad. Of Country Music v. Cont’l Cas. Co., 991 F.3d 1059, 1061 26 (9th Cir. 2021) (quoting Cal. ex rel. Lockyer v. Dynegy, Inc., 375 F.3d 831, 838 (9th Cir. 2004); 27 see also Provincial Gov’t of Marinduque v. Placer Dome, Inc., 582 F.3d 1083, 1087 (9th Cir. 28 2009) (“The defendant bears the burden of establishing that removal is proper.”). As such, a 1 federal court must reject jurisdiction and remand the case to state court if there is any doubt as to 2 the right of removal. Matheson v. Progressive Specialty Ins. Co., 319 F.3d 1089, 1090 (9th Cir. 3 2003). A “notice of removal ‘need not contain evidentiary submissions,’ but only plausible 4 allegations of the jurisdictional elements.” Arias v. Residence Inn by Marriott, 936 F.3d 920, 922 5 (9th Cir. 2019) (quoting Ibarra v. Manheim Investments, Inc., 775 F.3d 1193, 1197–99 (9th Cir. 6 2015)). 7 B. Diversity Jurisdiction 8 A court may exercise diversity jurisdiction over a matter when there is diversity of 9 citizenship among the parties and the amount in controversy exceeds $75,000. See 28 U.S.C. 10 § 1332(a). 11 i. Diversity of Citizenship 12 An action may be removed to federal court based on diversity jurisdiction only where 13 there is complete diversity of citizenship between the parties. Hunter v. Phillip Morris USA, 582 14 F.3d 1039, 1043 (9th Cir. 2009) (citing 28 U.S.C. §§ 1332(a), 1441(b)). For diversity purposes, a 15 person is a citizen of a state if he or she is: (1) a citizen of the United States and (2) domiciled in 16 that state. Kantor v. Wellesley Galleries, Ltd., 704 F.2d 1088, 1090 (9th Cir. 1983). An LLC is a 17 citizen of the state of which its owners or members are citizens. Johnson v. Columbia Props. 18 Anchorage, LP, 437 F.3d 894, 899 (9th Cir. 2006). A corporation is a citizen of the state in which 19 it is incorporated and the state in which its principal place of business is located. See, e.g., id. 20 (citing 28 U.S.C. § 1332(c)(1)). “In determining whether a civil action is removable on the basis 21 of [diversity jurisdiction], the citizenship of defendants sued under fictitious names shall be 22 disregarded.” 28 U.S.C. § 1441(b)(1). 23 ii. Amount in Controversy 24 A notice of removal must include “a plausible allegation that the amount in controversy 25 exceeds the jurisdictional threshold.” Dart Cherokee Basin Operating Co. v. Owens, 574 U.S. 81, 26 89 (2014). The amount in controversy is calculated based upon “the complaint operative at the 27 time of removal and encompasses all relief a court may grant on that complaint if the plaintiff is 28 victorious.” Chavez v. JPMorgan Chase & Co., 888 F.3d 413, 414–15 (9th Cir. 2018). “The 1 amount in controversy is simply an estimate of the total amount in dispute, not a prospective 2 assessment of defendant’s liability.” Lewis v. Verizon Commc’ns, Inc., 627 F.3d 395, 400 (9th 3 Cir. 2010) (citation omitted). 4 When the “plaintiff’s state court complaint does not specify a particular amount of 5 damages, the removing [party] bears the burden of establishing, by a preponderance of the 6 evidence, that the amount in controversy exceeds” the threshold amount of $75,000. Canela v. 7 Costco Wholesale Corp., 971 F.3d 845, 849 (9th Cir. 2020) (citation omitted). Courts begin their 8 inquiry by looking at the complaint, but “the amount-in-controversy inquiry in the removal 9 context is not confined to the face of the complaint.” Valdez v. Allstate Ins. Co., 372 F.3d 1115, 10 1117 (9th Cir.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Colbert Jr. v. General Motors LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/colbert-jr-v-general-motors-llc-caed-2025.