Downey v. FCA US LLC

CourtDistrict Court, D. New Mexico
DecidedMay 27, 2025
Docket1:25-cv-00487
StatusUnknown

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

Bluebook
Downey v. FCA US LLC, (D.N.M. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO PHILIP A. DOWNEY,1 Plaintiff, v. No. 1:25-cv-00487-LF2

FCA US LLC, Defendant. ORDER TO SHOW CAUSE Plaintiff asserts claims against Defendant pursuant to the Pennsylvania Unfair Trade Practices Act and Consumer Protection Law and the New Jersey Consumer Fraud Act, and for unjust enrichment. See Complaint, Doc. 1, filed May 23, 2025. Plaintiff also alleges that “Defendant’s authorized automobile dealerships act as Defendant’s agents in, inter alia, servicing automobiles under the Alfa Romeo name and disseminating vehicle information provided by Alfa Romeo to customers.” Complaint at 2. Plaintiff states:

his Alfa Romeo Stelvio’s engine [] inexplicably died with less than 60,0000 miles on the odometer, and despite having been regularly, and exclusively, serviced, at exorbitant costs at authorized Alfa Romeo dealerships. Alfa Romeo could not tell Plaintiff why his engine failed and refused to address his concerns that they are manufacturing and marketing a vehicle with an engine not engineered and designed to last a mere 60,000 miles!

1 The reference to “Plaintiff David Franco” is apparently a typographical error. Complaint at 3, ¶ 7. 2 The Clerk's Office assigned the undersigned to this case for review pursuant to 28 U.S.C. § 1915 which allows the Court to authorize commencement of a case without prepayment of the filing fee. See Doc. 2, filed May 23, 2025. Plaintiff has paid the filing fee. The undersigned has reviewed the Complaint pursuant to the Court's inherent power to manage its docket. See Securities and Exchange Comm'n v. Management Solutions, Inc., 824 Fed.Appx. 550, 553 (10th Cir. 2020) ("a district court has the inherent power 'to manage [its] own affairs so as to achieve the orderly and expeditious disposition of cases'”) (quoting Dietz v. Bouldin, 136 S. Ct. 1885, 1891-92 (2016)). Complaint at 1. Plaintiff asserts the Court has diversity jurisdiction over this matter. See Complaint at 4. Plaintiff states he is a resident of New Mexico, and that Defendant is a limited liability corporation organized under the laws of the State of Delaware and has its corporate headquarters in the State of Michigan. See Complaint at 1-2.

Plaintiff has not shown that the Court has diversity jurisdiction over this matter. Diversity jurisdiction requires that the action is between “citizens of different states.” 28 U.S.C. § 1332(a)(1). “An individual's residence is not equivalent to his domicile and it is domicile that is relevant for determining citizenship.” Siloam Springs Hotel, L.L.C. v. Century Sur. Co., 781 F.3d 1233, 1238 (10th Cir. 2015) (citing Whitelock v. Leatherman, 460 F.2d 507, 514 n. 14 (10th Cir.1972) (holding that “an allegation that a party defendant is a resident of a state is not equivalent to an allegation of citizenship and is insufficient to confer jurisdiction upon the District Court”)). We have described the citizenship inquiry as “an all-things-considered approach” in which “any number of factors might shed light on the subject in any given case.” [Middleton v. Stephenson, 749 F.3d 1197, 1201 (10th Cir. 2014)]. Relevant factors include

the party's current residence; voter registration and voting practices; situs of personal and real property; location of brokerage and bank accounts; membership in unions, fraternal organizations, churches, clubs, and other associations; place of employment or business; driver's license and automobile registration; payment of taxes; as well as several other aspects of human life and activity.

Id. (internal quotation marks omitted). Although a person's “place of residence is prima facie the domicile,” State Farm Mut. Auto. Ins. Co. v. Dyer, 19 F.3d 514, 520 (10th Cir. 1994), something more than residence in a state is required to show the intent to remain in the state, see Whitelock v. Leatherman, 460 F.2d 507, 514 (10th Cir. 1972) (“[A]llegations of mere ‘residence’ may not be equated with ‘citizenship.’”). Lax v. APP of New Mexico ED, PLLC, 2022 WL 2711230, *3-4 (10th Cir.). Plaintiff has not established that he is a citizen of New Mexico. Defendant is a limited liability company. A limited liability company is a citizen of each and every state in which any member is a citizen. See Siloam Springs Hotel, LLC v. Century Sur. Co., 781 F.3d 1233, 1237-38 (10th Cir. 2015) (“Supreme Court precedent makes clear that in

determining the citizenship of an unincorporated association for purposes of diversity, federal courts must include all the entities’ members”) (citing Carden v. Arkoma Assocs., 494 U.S. 185, 195-96 (1990). The Complaint does not allege the citizenship of Defendant’s members. Furthermore, it appears the District of New Mexico is not the proper venue for this action. Plaintiff states “[v]enue is appropriate in this court as the defendants regularly and purposefully conduct business in this judicial district.” Complaint at 3. The statute governing venue in general states: Venue in general.--A civil action may be brought in—

(1) a judicial district in which any defendant resides, if all defendants are residents of the State in which the district is located;

(2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of property that is the subject of the action is situated; or

(3) if there is no district in which an action may otherwise be brought as provided in this section, any judicial district in which any defendant is subject to the court's personal jurisdiction with respect to such action.

28 U.S.C. §1391(b). “The district court of a district in which is filed a case laying venue in the wrong division or district shall dismiss, or if it be in the interest of justice, transfer such case to any district or division in which it could have been brought.” 28 U.S.C. § 1406(a) (emphasis added). Factors considered in deciding whether a transfer is in the interests of justice include whether the claims would be barred by a statute of limitations if filed anew in the proper forum, e.g. Haugh v. Booker, 210 F.3d 1147, 1150 (10th Cir.2000) (citing Coleman v. United States, 106 F.3d 339, 341 (10th Cir.1997)), whether the claims alleged are likely to have merit, e.g.

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

Related

Carden v. Arkoma Associates
494 U.S. 185 (Supreme Court, 1990)
Haugh v. Booker
210 F.3d 1147 (Tenth Circuit, 2000)
Young v. State Govt Oklahoma
98 F. App'x 760 (Tenth Circuit, 2004)
Yang v. Archuleta
525 F.3d 925 (Tenth Circuit, 2008)
C. L. Whitelock v. Delbert Leatherman
460 F.2d 507 (Tenth Circuit, 1972)
Jerry Craig Coleman v. United States
106 F.3d 339 (Tenth Circuit, 1997)
Siloam Springs Hotel, L.L.C. v. Century Surety Co.
781 F.3d 1233 (Tenth Circuit, 2015)
Dietz v. Bouldin
579 U.S. 40 (Supreme Court, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Downey v. FCA US LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/downey-v-fca-us-llc-nmd-2025.