Fox v. DriveTime Automotive Group Incorporated

CourtDistrict Court, D. Arizona
DecidedJuly 16, 2025
Docket4:25-cv-00290
StatusUnknown

This text of Fox v. DriveTime Automotive Group Incorporated (Fox v. DriveTime Automotive Group Incorporated) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fox v. DriveTime Automotive Group Incorporated, (D. Ariz. 2025).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Jesse Fox, No. CV-25-00290-TUC-JGZ

10 Plaintiff, ORDER

11 v.

12 DriveTime Automotive Group Incorporated,

13 Defendant.

14 On June 12, 2025, Defendant DriveTime Car Sales Company, LLC1 removed this 15 action from Pima County Superior Court. (Doc. 1.) Pending before the Court is Plaintiff 16 Jesse Fox’s Motion to Remand to State Court and Request for Sanctions Pursuant to 28 17 U.S.C. § 1447(c). (Doc. 5.) The Motion is fully briefed. (See Docs. 7, 8.)2 For the following 18 reasons, the Court will grant Plaintiff’s Motion and remand this action to Pima County 19 Superior Court. 20 I. Removal 21 Generally, a defendant may remove to federal court “any civil action brought in a 22 State court of which the district courts . . . have original jurisdiction.” 28 U.S.C. § 1441. A 23 federal district court has original subject matter jurisdiction over a case involving a federal 24

25 1 Defendant asserts that the only named Defendant in Plaintiff’s Complaint, DriveTime Automotive Group, Inc., is not an appropriate party to this action because Plaintiff 26 contracted with DriveTime Car Sales Company. (Doc. 1 at 1 n.1.) Plaintiff does not dispute that DriveTime Car Sales Company is the proper defendant in this case. (Doc. 5 at 1 27 (naming DriveTime Car Sales Company as Defendant).) 2 On July 11, 2025, Plaintiff filed a supplemental reply that largely repeats arguments 28 made in his earlier briefing. (See Doc. 9.) The attached email from Defendant’s counsel with incomplete text does not affect the Court’s analysis. (See Doc. 9-1.) 1 question—i.e., any claim arising under the United States Constitution, federal law, or 2 treaty—or when the parties have complete diversity of citizenship and the amount in 3 controversy is over $75,000. Id. §§ 1331, 1332. “[T]he well-pleaded complaint rule 4 ‘provides that federal [question] jurisdiction exists only when a federal question is 5 presented on the face of the plaintiff’s properly pleaded complaint.” Hunter v. Philip 6 Morris USA, 582 F.3d 1039, 1042 (9th Cir. 2009) (quoting In re NOS Commc'ns, MDL No. 7 1357, 495 F.3d 1052, 1057 (9th Cir. 2007)). “[T]he plaintiff is ‘the master of the complaint’ 8 and may ‘avoid federal jurisdiction by relying exclusively on state law.’” Id. (quoting 9 Balcorta v. Twentieth Century-Fox Film Corp., 208 F.3d 1102, 1106 (9th Cir. 2000)). 10 There is a “strong presumption against removal jurisdiction[, which] means that the 11 defendant always has the burden of establishing that removal is proper, and that the court 12 resolves all ambiguity in favor of remand to state court.” Hunter v. Philip Morris USA, 582 13 F.3d 1039, 1042 (9th Cir. 2009) (internal quotation marks omitted) (quoting Gaus v. Miles, 14 Inc., 980 F.2d 564, 566 (9th Cir. 1992)). 15 Here, Defendant bases its removal request on federal question jurisdiction3 because 16 “Plaintiff alleges violations of the Fair Debt Collections Practice Act, 15 U.S.C. § 1692, et 17 seq. [“FDCPA”].” (Doc. 1 at 1.) Plaintiff argues his Complaint pleads only state law claims 18 for breach of contract, quiet title, and violations of Arizona consumer protection statutes, 19 and that the Complaint briefly references the FDCPA for comparison, but “no federal claim 20 is asserted.” (Doc. 5 at 2.) Defendant argues the FDCPA claim is listed “alongside the rest 21 of Plaintiff’s claims (which are not set out anywhere else),” and Plaintiff discussed alleged 22 FDCPA violations in emails sent to a non-party entity, Bridgecrest. (Doc. 7 at 3–4.) 23 Defendant fails to meet its burden of establishing that removal is proper on the basis 24 of federal question jurisdiction.4 First, contrary to Defendant’s characterization, it is far

25 3 Diversity jurisdiction appears to be lacking as Plaintiff’s Complaint states it is seeking less than $50,000 in damages and Plaintiff alleges the parties are not diverse. (Doc. 1-1 at 26 5; Doc. 5 at 3.) In any event, Defendant has not invoked diversity jurisdiction as a basis for removal. (Doc. 7 at 3 n.3); see Hunter, 582 F.3d at 1042 (“[T]he defendant always has the 27 burden of establishing that removal is proper.”). 4 Because the Court finds remand appropriate on this basis, the Court does not address 28 Plaintiff’s alternative arguments regarding bad faith and procedural defects. (See Doc. 5 at 4.) 1 from clear that each of the eight paragraphs in the Complaint’s section entitled 2 “APPLICABLE LAW SUPPORTING CLAIMS” allege distinct causes of action, or that 3 Plaintiff intended as much when he filed the Complaint. (See Doc. 1-1 ¶¶ 24–31.) The 4 Arizona Supreme Court’s pro se “Civil Complaint” form, which Plaintiff used to file his 5 Complaint, does not provide an obvious location for numerically listing causes of action, 6 and “applicable law supporting claims” does not necessarily equate to a legal claim or 7 cause of action itself. (See Doc. 1-1 at 4–10.) Moreover, the form provides unlabeled blank 8 spaces on the first page next to the parties’ names and case number. (Id. at 4.) Thus, it was 9 understandable, if not reasonable, for Plaintiff to list his causes of action in the unlabeled 10 blank spaces on the first page and to use the “APPLICABLE LAW SUPPORTING 11 CLAIMS” section to list all legal authority that may support his claims. (Doc. 1-1 at 4, 6, 12 9; Doc. 5 at 2–3 (“The FDCPA is mentioned only to illustrate how Arizona consumer laws 13 mirror federal standards.”).) As master of the complaint, Plaintiff is entitled to rely 14 exclusively on state law and has chosen to do so here. See Balcorta, 208 F.3d at 1106; 15 (Doc. 5 at 3); (Doc. 1-1 at 4 (listing state-law claims for “Breach of Contract,” “Quiet 16 Title,” and “Violation of Arizona Consumer Protection”)). 17 Moreover, Defendant’s characterization of Plaintiff’s claims is unconvincing.5 For 18 example, Defendant asserts Plaintiff alleges a claim for breach of contract in the 19 “APPLICABLE LAW SUPPORTING CLAIMS” section, but the words “breach of 20 contract” are not included in that section; rather, “Breach of Contract” appears on the first 21 page of the Complaint. (Doc. 1-1 at 1, 6, 9, ¶¶ 24–31.) Also, Defendant does not mention 22 Paragraph 25, which states, “Restatement of Contracts § 205 – Reinforces the duty of good 23 faith and fair dealing in all contractual performance.” (Id. ¶ 25.) If Plaintiff intended each 24 paragraph of the “APPLICABLE LAW SUPPORTING CLAIMS” section to allege a cause 25 of action, then the Complaint alleges one violation of the obligation of good faith and fair 26 dealing under A.R.S. § 47-1304, and one violation of the obligation of good faith and fair 27 5 Defendant argues the Complaint “alleges eight claims for relief,” apparently 28 corresponding to the eight paragraphs in the “APPLICABLE LAW SUPPORTING CLAIMS” section, but then lists only seven claims. (Doc. 7 at 1–2.) 1 dealing under Restatement of Contracts § 205. It is more likely that Plaintiff intended to 2 list a provision of the Restatement (and A.R.S. § 47-1304

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Fox v. DriveTime Automotive Group Incorporated, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fox-v-drivetime-automotive-group-incorporated-azd-2025.