Isela Hernandez v. FCA US, LLC

CourtDistrict Court, C.D. California
DecidedJune 29, 2020
Docket2:20-cv-01058
StatusUnknown

This text of Isela Hernandez v. FCA US, LLC (Isela Hernandez 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
Isela Hernandez v. FCA US, LLC, (C.D. Cal. 2020).

Opinion

1 2 JS6 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 12 ISELA HERNANDEZ, an ) CV 20-1058-RSWL-MAA individual, ) 13 ) Plaintiff, ) ORDER re: Plaintiff’s 14 ) Motion to Remand [8] ) 15 v. ) ) 16 ) FCA US, LLC, a Delaware ) 17 Limited Liability Company; ) and DOES 1 through 20, ) 18 inclusive, ) ) 19 Defendants. 20 Plaintiff Isela Hernandez (“Plaintiff”) brings this 21 Action against Defendant FCA US, LLC (“Defendant”) for 22 violations of California's Song-Beverly Consumer 23 Warranty Act (the “Song-Beverly Act”). Currently 24 before the Court is Plaintiff’s Motion to Remand 25 (“Motion”) [8]. Having reviewed all papers submitted 26 pertaining to the Motion, the Court NOW FINDS AND RULES 27 AS FOLLOWS: GRANTS Plaintiff’s Motion. 28 /// 1 I. BACKGROUND 2 A. Factual Background 3 Plaintiff alleges Defendant manufactured and/or 4 distributed a 2015 Jeep Grand Cherokee, Vehicle 5 Identification Number 1C4RJECG9FC915303 (the 6 “Vehicle”). Ex. A to Decl. of Barbara R. Adams in 7 Supp. of Notice of Removal, Compl., ¶ 4 (“Compl.”), ECF 8 No. 1-1. Plaintiff alleges she leased the Vehicle on 9 or about May 10, 2016. Id. ¶ 5. 10 Plaintiff alleges that the Vehicle developed 11 various defects, including issues with the canister 12 software, water leaks, an inoperable passenger seat, 13 and an unstable engine, among multiple others. Id. ¶ 14 10. Plaintiff further alleges she delivered the 15 Vehicle to Defendant's authorized service and repair 16 facilities on at least ten occasions. Id. ¶ 9. 17 Plaintiff alleges that Defendant failed to conform the 18 Vehicle to the applicable warranties as shown by the 19 defects existing after a reasonable number of repair 20 attempts. Id. ¶ 12. 21 B. Procedural Background 22 Plaintiff filed her Complaint [1-1] in the Superior 23 Court of the State of California, County of Los 24 Angeles, on December 19, 2019, alleging Defendant 25 violated the Song-Beverly Act. Defendant removed this 26 Action to this Court on January 1, 2020 [1]. Plaintiff 27 filed the instant Motion to Remand [8] on April 20, 28 2020. Defendant filed its Opposition [9] on April 28, 1 2020, and Plaintiff replied [10] on May 5, 2020. 2 II. DISCUSSION 3 A. Legal Standard 4 Civil actions may be removed from state court if 5 the federal court has original jurisdiction. See 6 Syngenta Crop Prot., Inc. v. Henson, 537 U.S. 28, 33 7 (2002) (“Under the plain terms of § 1441(a), in order 8 properly to remove [an] action pursuant to that 9 provision, . . . original subject-matter jurisdiction 10 [must] lie[] in the federal courts.”). Diversity 11 jurisdiction exists in all civil actions between 12 citizens of different states where the amount in 13 controversy exceeds $75,000, exclusive of interest and 14 costs. 28 U.S.C. § 1332. There must be complete 15 diversity of citizenship, meaning “each of the 16 plaintiffs must be a citizen of a different state than 17 each of the defendants.” Morris v. Princess Cruises, 18 Inc., 236 F.3d 1061, 1067 (9th Cir. 2001) (citing 19 Caterpillar Inc. v. Lewis, 519 U.S. 61, 68 (1996)). 20 Federal question jurisdiction exists in “all civil 21 actions arising under the Constitution, laws, or 22 treaties of the United States.” 28 U.S.C. § 1331. 23 “The burden of establishing jurisdiction falls on 24 the party invoking the removal statute, which is 25 strictly construed against removal.” Sullivan v. First 26 Affiliated Sec., Inc., 813 F.2d 1368, 1371 (9th Cir. 27 1987) (internal citations omitted). Courts resolve all 28 ambiguities “in favor of remand to state court.” 1 Hunter v. Philip Morris USA, 582 F.3d 1039, 1042 (9th 2 Cir. 2009) (citing Gaus v. Miles, Inc., 980 F.2d 564, 3 566 (9th Cir. 1992)). A removed case must be remanded 4 “[i]f at any time before final judgment it appears that 5 the district court lacks subject matter jurisdiction.” 6 28 U.S.C. § 1447(c). 7 B. Discussion 8 Plaintiff contends that this Court lacks subject 9 matter jurisdiction over this Action so it should be 10 remanded to state court.1 The Court undisputably lacks 11 federal question jurisdiction; therefore, the issue is 12 whether the Court has diversity jurisdiction. 13 1. Amount in Controversy 14 When a defendant removes a complaint to federal 15 court, the defendant’s burden with respect to the 16 1 In addition to lack of subject matter jurisdiction, 17 Plaintiff argues that this Action should be remanded because Defendant failed to give notice to the Los Angeles Superior Court 18 that the case had been remanded. See Mot. 6:16-20, ECF No. 8. Specifically, Plaintiff contends that the “Notice of Removal 19 states that Plaintiff filed this action in the Superior Court of the State of California for the County of San Luis Obispo,” and 20 that a copy of the Notice of Removal “ will be provided to the 21 Clerk of the San Luis Obispo Superior Court.” Id. at 6:9-15. Plaintiff maintains that the Notice of Removal is thereby 22 procedurally defective because this Action was originally filed in the Los Angeles Superior Court. Id. at 6:18-20. But, 23 Defendant, in its Opposition, clarified that the reference to the San Luis Obispo Superior Court was a typographical error, and 24 insisted that proper notice was provided to the Los Angeles Superior Court. See Opp’n 4:7-12, ECF No. 9. The Court finds 25 that proper notice was provided to the Los Angeles Superior Court on January 31, 2020, see Ex. 2 in Supp. of Opp’n, ECF No. 9-3, 26 and that an amended notice was also given to the Los Angeles 27 Superior Court on February 7, 2020, see Ex. 3 in Supp. of Opp’n, ECF No. 9-4. Accordingly, the Court DENIES Plaintiff’s Motion as 28 it related to the argument that remand is proper because notice was not provided to the Los Angeles Superior Court. 1 amount in controversy varies depending on the 2 circumstances. Guglielmino v. McKee Foods Corp., 506 3 F.3d 696, 699 (9th Cir. 2007). But “where it is 4 unclear or ambiguous from the face of a state-court 5 complaint whether the requisite amount in controversy 6 is pled,” the applicable standard is by a preponderance 7 of the evidence; this requires that the defendant offer 8 evidence establishing that it is more likely than not 9 that the amount in controversy is met, exclusive of 10 costs and interest. Id. (citing Sanchez v. Monumental 11 Life Ins. Co., 102 F.3d 398, 404 (9th Cir. 1996)). In 12 considering whether the removing defendant has 13 satisfied its burden, the court “may consider facts in 14 the removal petition,” and “‘summary-judgment-type 15 evidence relevant to the amount in controversy at the 16 time of removal.’” Singer v State Farm Mut. Auto. Ins. 17 Co., 116 F.3d 373, 377 (9th Cir. 1997) (quoting Allen 18 v. R & H Oil & Gas. Co., 63 F.3d 1326, 1335-36 (5th 19 Cir. 1995)).

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Bluebook (online)
Isela Hernandez v. FCA US, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/isela-hernandez-v-fca-us-llc-cacd-2020.