Graciela Carrillo v. FCA US LLC

CourtDistrict Court, C.D. California
DecidedMay 1, 2020
Docket5:20-cv-00481
StatusUnknown

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

Bluebook
Graciela Carrillo v. FCA US LLC, (C.D. Cal. 2020).

Opinion

UNITED STATES DISTRICT COURT JS-6 CENTRAL DISTRICT OF CALIFORNIA CIVIL MINUTES—GENERAL

Case No. EDCV 20-481 JGB (SHKx) Date May 1, 2020 Title Graciela Carrillo, et al. v. FCA US LLC, et al.

Present: The Honorable JESUS G. BERNAL, UNITED STATES DISTRICT JUDGE

MAYNOR GALVEZ Not Reported Deputy Clerk Court Reporter

Attorney(s) Present for Plaintiff(s): Attorney(s) Present for Defendant(s): None Present None Present

Proceedings: Order (1) GRANTING Plaintiffs’ Motion for Remand (Dkt. No. 11); and (2) VACATING the May 4, 2020 Hearing (IN CHAMBERS) Before the Court is Motion for Remand filed by Plaintiffs Graciela Carrillo and Teresa Carrillo. (“Motion,” Dkt. No. 11.) The Court finds the Motion appropriate for resolution without a hearing. See Fed. R. Civ. P. 78; L.R. 7-15. After considering the papers filed in support of and in opposition to the Motion, the Court GRANTS the Motion. The Court VACATES the hearing set for May 4, 2020.

I. BACKGROUND

On February 5, 2020, Plaintiffs filed their Complaint in the Superior Court of the State of California for the County of Riverside against Defendants Moss Bros. CJD Inc. (“Moss”), FCA US LLC (“FCA”), and Does 1–10. (“Complaint,” Dkt. No. 1-4.) The Complaint alleges four causes of action: (1) Violation of Song-Beverly Act – Breach of Express Warranty, (2) Violation of Song-Beverly Act – Breach of Implied Warranty, (3) Violation of Song-Beverly Act Section 1793.2, and (4) Negligent Repair. (Complaint.)

On March 9, 2020, Defendant FCA removed the action to federal court. (“Notice of Removal,” Dkt. No. 1.) Plaintiff filed the Motion on April 3, 2020. (Motion.) Defendant opposed the Motion on April 13, 2020. (“Opposition,” Dkt. No. 13.) Plaintiff replied in support of the Motion on April 17, 2020. (“Reply,” Dkt. No. 14.)

// // // II. LEGAL STANDARD

Pursuant to 28 U.S.C. § 1441(a), a defendant may remove a matter to federal court where the district court would have original jurisdiction. Caterpillar, Inc. v. Williams, 482 U.S. 386, 392 (1987). Federal courts have limited jurisdiction, “possessing only that power authorized by Constitution and statute.” Gunn v. Minton, 568 U.S. 251, 256 (2013). As such, a defendant may remove civil actions in which a federal question exists or in which complete diversity of citizenship between the parties exists and the amount in controversy exceeds $75,000. See 28 U.S.C. §§ 1331, 1332. “Complete diversity” means that “each defendant must be a citizen of a different state from each plaintiff.” In re Digimarc Corp. Derivative Litigation, 549 F.3d 1223, 1234 (9th Cir. 2008).

The right to remove is not absolute, even where original jurisdiction exists. A defendant may not remove on diversity jurisdiction grounds “if any of the parties in interest properly joined and served as defendants is a citizen of the State in which such an action is brought.” 28 U.S.C. § 1441(b)(2). And a defendant must remove “within 30 days after the receipt by the defendant, through service or otherwise, of a copy of the initial pleading.” 28 U.S.C. § 1446(b).

Moreover, the Ninth Circuit “strictly construe[s] the removal statute against removal jurisdiction,” and “[f]ederal jurisdiction must be rejected if there is any doubt as to the right of removal in the first instance.” Gaus v. Miles, Inc., 980 F.2d 564, 566 (9th Cir. 1992). “The strong presumption against removal jurisdiction means that the defendant always has the burden of establishing that removal is proper.” Jackson v. Specialized Loan Servicing, LLC, 2014 WL 5514142, *6 (C.D. Cal. Oct. 31, 2014). The court must resolve doubts regarding removability in favor of remanding the case to state court. Id.

III. DISCUSSION

Defendant FCA removed this action on the basis of diversity jurisdiction. (Notice of Removal at 1.) While Plaintiffs appear to concede that the amount in controversy exceeds $75,000, they argue that the case ought to be remanded because there is not complete diversity between the parties: like Plaintiffs, Defendant Moss is a citizen of California. (Motion at 3–8.)

Defendant FCA argues that Defendant Moss’s joinder was a fraudulent—done solely for the purpose of defeating diversity jurisdiction—and therefore should not be considered in determining diversity jurisdiction. (Opposition at 5–6.); Grancare, LLC v. Thrower by & through Mills, 889 F.3d 543, 548 (9th Cir. 2018) (“In determining whether there is complete diversity, district courts may disregard the citizenship of a non-diverse defendant who has been fraudulently joined.”). Defendant FCA can establish fraudulent joinder by demonstrating either: “(1) actual fraud in the pleading of jurisdictional facts, or (2) [the] inability of the plaintiff to establish a cause of action against the non-diverse party in state court.” Hunter v. Philip Morris USA, 582 F.3d 1039, 1044 (9th Cir. 2009). Because there is a “general presumption against [finding] fraudulent joinder,” Defendant FCA must bear a “heavy burden” to demonstrate that there is diversity jurisdiction despite the joinder of Defendant Moss. See id. Defendant has failed to meet that heavy burden. First, while Defendant FCA suggests that there may have been fraud in the pleading of the jurisdictional facts, it fails to identify which facts were fraudulently pled or to proffer evidence showing actual fraud. (See Opposition at 5–6.)

Second, Defendant FCA fails to prove that Plaintiffs cannot sustain any cause of action against Defendant Moss. In the Complaint, Plaintiffs bring a single cause of action against Defendant Moss: negligent repair. (Complaint.) To prove that Plaintiffs cannot sustain any cause of action against Defendant Moss, Defendant FCA must do more than show that the negligent repair claim fails under Rule 12(b)(6).1 Grancare, LLC v. Thrower by & through Mills, 889 F.3d 543, 550 (9th Cir. 2018). Defendant FCA must prove that there is no possibility that (1) the negligent repair claim would survive in the state court or (2) that it could “possibly be cured by granting the plaintiff leave to amend.” Id.

Defendant FCA argues that Plaintiffs’ negligent repair claim is barred by the economic loss rule. (Opposition at 5–6.) The economic loss rule generally precludes tort claims for purely economic damages. S.M. Wilson & Co. v. Smith Int’l, Inc., 587 F.2d 1363, 1376 (9th Cir. 1978). Defendant FCA insists that the economic loss rule applies because “Plaintiffs have not alleged that Moss Bros Chrysler’s negligent repair work caused personal injuries or damaged their property.” (Opposition at 5.) However, it is entirely plausible that Plaintiffs could amend their complaint and include allegations regarding damage to their property caused by the negligent repair. See Gorelick v.

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Related

Caterpillar Inc. v. Williams
482 U.S. 386 (Supreme Court, 1987)
Martin v. Franklin Capital Corp.
546 U.S. 132 (Supreme Court, 2005)
S. M. Wilson & Company v. Smith International, Inc.
587 F.2d 1363 (Ninth Circuit, 1978)
Gunn v. Minton
133 S. Ct. 1059 (Supreme Court, 2013)
Hunter v. Philip Morris USA
582 F.3d 1039 (Ninth Circuit, 2009)
In Re Digimarc Corp. Derivative Litigation
549 F.3d 1223 (Ninth Circuit, 2008)
Grancare v. Ruth Thrower
889 F.3d 543 (Ninth Circuit, 2018)

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Bluebook (online)
Graciela Carrillo v. FCA US LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/graciela-carrillo-v-fca-us-llc-cacd-2020.