Farrales v. Ford Motor Company

CourtDistrict Court, N.D. California
DecidedApril 27, 2022
Docket4:21-cv-07624
StatusUnknown

This text of Farrales v. Ford Motor Company (Farrales v. Ford Motor Company) 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
Farrales v. Ford Motor Company, (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 EDDY FARRALES, Case No. 21-cv-07624-HSG 8 Plaintiff, ORDER DENYING MOTION TO REMAND AND GRANTING MOTION 9 v. FOR JUDGMENT ON THE PLEADINGS 10 FORD MOTOR COMPANY, Re: Dkt. Nos. 12, 21 11 Defendant. 12 13 Pending before the Court is a motion to remand filed by Plaintiff Eddy Farrales and a 14 motion for judgment on the pleadings filed by Defendant Ford Motor Company. See Dkt. Nos. 15 12, 21. The Court finds these matters appropriate for disposition without oral argument and the 16 matters are deemed submitted. See Civil L.R. 7-1(b). For the reasons detailed below, the Court 17 DENIES the motion to remand and GRANTS the motion for judgment on the pleadings with 18 leave to amend. 19 I. BACKGROUND 20 Plaintiff filed this action in San Francisco County Superior Court in September 2021. See 21 Dkt. No. 1-3. Plaintiff alleges that he purchased a vehicle manufactured by Ford. See Dkt. No. 1- 22 4 (“FAC”) at ¶¶ 4–5. The vehicle was covered by an express warranty, under which Ford 23 undertook to maintain the utility and performance of the vehicle or to provide compensation in the 24 event of a failure in utility or performance. Id. at ¶ 6. Accordingly, Plaintiff could deliver the 25 vehicle to Ford’s representative for repair in the event of a defect during the warranty period. Id. 26 Plaintiff identifies several defects that developed during the warranty period that impaired 27 the use, value, or safety of the vehicle. See id. at ¶ 7. However, Plaintiff alleges that Ford did not 1 ¶¶ 8–9. Based on these allegations, Plaintiff asserts several causes of action, including for breach 2 of express and implied warranties under the Song-Beverly Consumer Warranty Act, Cal. Civ. 3 Code §§ 1790 et seq. (the “Song-Beverly Act”). See id. at ¶¶ 10–71. Plaintiff seeks actual 4 damages, civil penalties of no more than two times his actual damages under California Civil 5 Code § 1794(c), punitive damages, as well as attorneys’ fees and costs. See id., Prayer for Relief. 6 Ford removed this action in September, asserting diversity jurisdiction. See Dkt. No. 1. 7 Plaintiff now seeks to remand the action back to state court. Dkt. No. 12. 8 II. MOTION TO REMAND 9 A. Legal Standard 10 “Except as otherwise expressly provided by Act of Congress, any civil action brought in a 11 State court of which the district courts of the United States have original jurisdiction, may be 12 removed” to federal court. 28 U.S.C. § 1441(a). District courts have original jurisdiction over 13 civil actions between citizens of different states in which the amount in controversy exceeds 14 $75,000. See 28 U.S.C. § 1332(a)(1). 15 If the district court lacks jurisdiction over an action, a plaintiff may seek remand to state 16 court. See 28 U.S.C. § 1447(c). There is a “strong presumption” in favor of remand, and 17 “[f]ederal jurisdiction must be rejected if there is any doubt as to the right of removal in the first 18 instance.” Guas v. Miles, Inc., 980 F.2d 564, 566 (9th Cir. 1992). Accordingly, “[t]he strong 19 presumption against removal jurisdiction means that the defendant always has the burden of 20 establishing that removal is proper . . . .” Hunter v. Philip Morris USA, 582 F.3d 1039, 1042 (9th 21 Cir. 2009). 22 B. Discussion 23 Here, the parties appear to agree that complete diversity of citizenship between the parties 24 has been established. Compare Dkt. No. 12, with Dkt. No. 15 at 5.1 According to the complaint, 25 26 1 The Court notes that in reviewing the parties’ briefs, it is apparent that counsel did not comply with Civil L.R. 3-4(c)(2), which requires 12-point type for all text, including footnotes. The Court 27 expects counsel to scrupulously comply with the Local Rules and the Court’s standing orders in all 1 Plaintiff is a resident of California and Ford is a corporation organized under the laws of 2 Delaware. See FAC at ¶¶ 1–2. Ford also confirms that its principal place of business is Michigan. 3 See Dkt. No. 1 at ¶ 16. Therefore, the only dispute is whether the $75,000 amount in controversy 4 is satisfied. “[W]hen a complaint filed in state court alleges on its face an amount in controversy 5 sufficient to meet the federal jurisdictional threshold, such requirement is presumptively satisfied 6 unless it appears to a legal certainty that the plaintiff cannot actually recover that amount.” 7 Guglielmino v. McKee Foods Corp., 506 F.3d 696, 699 (9th Cir. 2007). If, however, “it is unclear 8 or ambiguous from the face of a state-court complaint whether the requisite amount in controversy 9 is pled,” the removing defendant bears the burden of establishing by a “preponderance of the 10 evidence” that it is “more likely than not” that the amount in controversy exceeds $75,000. Id. at 11 699. 12 The FAC does not specify the amount of damages Plaintiff is seeking. Rather, the Prayer 13 for Relief simply lists generic requests for damages, including “actual economic damages 14 (including the right of restitution, incidental damages, and consequential damages),” “civil penalty 15 damages of no more than two times Plaintiff’s actual damages,” “punitive damages,” and “costs 16 and expenses, including Plaintiff’s attorney’s fees . . . .” See FAC, Prayer for Relief. Because the 17 amount in controversy is unclear from the face of the complaint, Ford must show by a 18 preponderance of the evidence that the amount in controversy exceeds $75,000. 19 In its notice of removal, Ford provided evidence that the sale price of the vehicle was 20 $45,800.60. See Dkt. No. 1 at ¶ 24. Ford further pointed out that Plaintiff seeks civil penalties up 21 to two times the amount of actual damages as well as attorneys’ fees and costs under the Song- 22 Beverly Act. See id. at ¶¶ 24–26; see also FAC at ¶ 20. Ford therefore posits that the alleged 23 damages and civil penalty alone total $137,401.80.2 See Dkt. No. 1 at ¶ 28. In the motion to 24 remand, Plaintiff does not offer his own estimate, but simply disputes Ford’s calculation and 25 proffered evidence.3 See Dkt. No. 12. 26 2 $45,800.60 (the purchase price of the vehicle) + $91,601.20 (a penalty of two times the purchase 27 price under the Song-Beverly Act) = $137,401.80. 1 i. Actual Damages 2 In his motion to remand, Plaintiff contends that Ford has improperly inflated the damages 3 that he seeks in this case. See Dkt. No. 12 at 3–5. Under the Song-Beverly Act “the manufacturer 4 shall make restitution [for the vehicle] in an amount equal to the actual price paid or payable by 5 the buyer . . . .” Cal. Civ. Code § 1793.2(d)(2)(B). 6 But Plaintiff argues that in calculating the restitution amount, Ford has failed to consider 7 required offsets for Plaintiff’s use of the vehicle. See Dkt. No. 12 at 3–4. Any amount of 8 restitution under the Act “may be reduced by the manufacturer by that amount directly 9 attributable to use by the buyer prior to the time the buyer first delivered the vehicle to the 10 manufacturer or distributor, or its authorized service and repair facility for correction of the 11 problem that gave rise to the nonconformity.” See Cal. Civ. Code § 1793.2(d)(2)(C) (emphasis 12 added).

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