Herko v. FCA US LLC

CourtDistrict Court, S.D. California
DecidedOctober 30, 2019
Docket3:19-cv-02057
StatusUnknown

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

Bluebook
Herko v. FCA US LLC, (S.D. Cal. 2019).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 HEATHER HERKO, a Natural Person, Case No.: 19-CV-2057 JLS (WVG)

12 Plaintiff, ORDER REMANDING ACTION TO 13 v. THE SUPERIOR COURT FOR THE STATE OF CALIFORNIA, COUNTY 14 FCA US, LLC, a limited liability OF SAN DIEGO company; and DOES 1 through 20, 15 inclusive, (ECF No. 1) 16 Defendants. 17

18 Presently before the Court is Defendant FCA US, LLC’s Notice of Removal to the 19 United States District Court for the Southern District of California Under 28 U.S.C. § 1332 20 (Diversity Jurisdiction) (“Not. of Removal,” ECF No. 1). On October 25, 2019, Defendant 21 removed this action from the Superior Court for the State of California, County of San 22 Diego on the grounds that “it involves citizens of different states, and the amount in 23 controversy exceeds $75,000, exclusive of interest and costs.” See id. ¶ 4. 24 Although Plaintiff Heather Herko did not file a motion to remand, “[t]he court 25 may—indeed must—remand an action sua sponte if it determines that it lacks subject 26 matter jurisdiction.” GFD, LLC v. Carter, No. CV 12-08985 MMM FFMX, 2012 WL 27 5830079, at *2 (C.D. Cal. Nov. 15, 2012) (citing Kelton Arms Condominium Owners Ass’n 28 v. Homestead Ins. Co., 346 F.3d 1190, 1192 (9th Cir. 2003)); see also 28 U.S.C. § 1447(c) 1 (“If at any time before final judgment it appears that the district court lacks subject matter 2 jurisdiction, the case shall be remanded.”). 3 “Federal courts are courts of limited jurisdiction. They possess only that power 4 authorized by Constitution and statute.” Kokkonen v. Guardian Life Ins. Co. of Am., 511 5 U.S. 375, 377 (1994). Consequently, it is “presume[d] that federal courts lack jurisdiction 6 unless the contrary appears affirmatively from the record.” DaimlerChrysler Corp. v. 7 Cuno, 547 U.S. 332, 342 (2006) (quoting Renne v. Geary, 501 U.S. 312, 316 (1991)). “The 8 right of removal is entirely a creature of statute and a suit commenced in a state court must 9 remain there until cause is shown for its transfer under some act of Congress.” Syngenta 10 Crop Protection, Inc. v. Henson, 537 U.S. 28, 32 (2002). The party invoking the removal 11 statute bears the burden of establishing that federal subject-matter jurisdiction exists. 12 Emrich v. Touche Ross & Co., 846 F.2d 1190, 1195 (9th Cir. 1988). Moreover, courts 13 “strictly construe the removal statute against removal jurisdiction.” Gaus v. Miles, Inc., 14 980 F.2d 564, 566 (9th Cir. 1992) (citing Boggs v. Lewis, 863 F.2d 662, 663 (9th Cir. 15 1988)); Takeda v. Nw. Nat’l Life Ins. Co., 765 F.2d 815, 818 (9th Cir. 1985)). Therefore, 16 “[f]ederal jurisdiction must be rejected if there is any doubt as to the right of removal in 17 the first instance.” Gaus, 980 F.2d at 566 (citing Libhart v. Santa Monica Dairy Co., 592 18 F.2d 1062, 1064 (9th Cir. 1979)). 19 Federal courts have diversity jurisdiction “where the amount in controversy” 20 exceeds $75,000, and the parties are of “diverse” state citizenship. 28 U.S.C. § 1332. 21 “Where it is not facially evident from the complaint that more than $75,000 is in 22 controversy, the removing party must prove, by a preponderance of the evidence, that the 23 amount in controversy meets the jurisdictional threshold.” Matheson v. Progressive 24 Specialty Ins. Co., 319 F.3d 1089, 1090 (9th Cir. 2003) (per curiam); accord Valdez v. 25 Allstate Ins. Co., 372 F.3d 1115, 1117 (9th Cir. 2004) (quoting Matheson, 319 F.3d at 26 1090). “Where doubt regarding the right to removal exists, a case should be remanded to 27 state court.” Matheson, 319 F.3d at 1090. 28 / / / 1 Here, the underlying Complaint indicates that, “[o]n or about March 17, 2014, 2 Plaintiff purchased a 2014 Jeep Grand Cherokee . . . . [for] $54,393.84.” See ECF No. 1- 3 2 (“Compl.”) ¶ 4. Plaintiff also alleges that “Defendant’s failure to comply with its 4 obligation[s] under the express warranty [and § 1793.2(d)] was willful” and, 5 “[a]ccordingly, Plaintiff is entitled to a civil penalty of two times Plaintiff’s actual damages 6 pursuant to Civil Code § 1794(c).” Id. ¶¶ 21, 27; see also id. at Prayer ¶¶ 3, 5. Plaintiff 7 also seeks her “costs of the suit and . . . reasonable attorney fees, pursuant to Civil Code 8 § 1794.” Id. at Prayer ¶ 7. Because it is not facially evident from the Complaint that the 9 amount in controversy exceeds $75,000, it is Defendant’s burden to prove, by a 10 preponderance of the evidence, that the amount in controversy exceeds the $75,000 11 jurisdictional threshold. See Matheson, 319 F.3d at 1090. 12 Defendant’s Notice of Removal contends that removal is proper because “[t]he total 13 sales price of the Subject Vehicle was $54,393.84,” Not. of Removal ¶ 13(ii), meaning 14 “Plaintiff . . . seeks $163,181.52 in damages” given her “alleg[ation] that she is entitled to 15 a civil penalty of up to two times the amount of actual damages,” “along with reasonable 16 attorney fees.” Not. of Removal ¶ 13(iv). Defendant cites Brady v. Mercedes-Benz USA, 17 Inc., 243 F. Supp. 2d 1004 (N.D. Cal. 2002), to support its contention that “civil penalties 18 under [the] California Song-Beverly Consumer Warranty Act are included in determining 19 whether [the] amount in controversy for diversity jurisdiction was satisfied as civil 20 penalties under the Act, allowing up to two times the amount of actual damages as well as 21 compensatory damages, are akin to punitive damages.” Not. of Removal ¶ 14 (citing 22 Brady, 243 F. Supp. 2d at 1009). 23 But it is this similarity to punitive damages that courts within this District have found 24 problematic. Courts have found that, where a plaintiff seeks punitive damages in her 25 complaint, the “[d]efendant’s burden cannot be met simply by pointing out that the 26 complaint seeks punitive damages and that any damages awarded under such a 27 claim could total a large sum of money, particularly in light of the high burden that must 28 be met in order for a plaintiff even to be eligible for receipt of discretionary punishment.” 1 Zawaideh v. BMW of N. Am., LLC, No. 17-CV-2151 W (KSC), 2018 WL 1805103, at *2 2 (S.D. Cal. Apr. 17, 2018) (quoting Conrad Assocs. v. Hartford Accident & Indem. Co., 994 3 F. Supp. 1196, 1201 (N.D. Cal. 1998)) (emphasis in original). Consequently, “[i]n 4 evaluating whether to include a civil penalty in calculating the amount in controversy . . .

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Related

Renne v. Geary
501 U.S. 312 (Supreme Court, 1991)
Syngenta Crop Protection, Inc. v. Henson
537 U.S. 28 (Supreme Court, 2002)
DaimlerChrysler Corp. v. Cuno
547 U.S. 332 (Supreme Court, 2006)
Matheson v. Progressive Specialty Insurance Company
319 F.3d 1089 (Ninth Circuit, 2003)
Brady v. Mercedes-Benz USA, Inc.
243 F. Supp. 2d 1004 (N.D. California, 2002)
Johnson v. America Online, Inc.
280 F. Supp. 2d 1018 (N.D. California, 2003)
The Hampton
5 U.S. 372 (Supreme Court, 1866)
Galt G/S v. JSS Scandinavia
142 F.3d 1150 (Ninth Circuit, 1998)
Takeda v. Northwestern National Life Insurance
765 F.2d 815 (Ninth Circuit, 1985)
Emrich v. Touche Ross & Co.
846 F.2d 1190 (Ninth Circuit, 1988)

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Bluebook (online)
Herko v. FCA US LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/herko-v-fca-us-llc-casd-2019.