Krikorian v. Ford Motor Company

CourtDistrict Court, S.D. Alabama
DecidedNovember 6, 2019
Docket1:19-cv-00582
StatusUnknown

This text of Krikorian v. Ford Motor Company (Krikorian v. Ford Motor Company) is published on Counsel Stack Legal Research, covering District Court, S.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Krikorian v. Ford Motor Company, (S.D. Ala. 2019).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

SAM KRIKORIAN, ) Plaintiff, ) ) v. ) CIVIL ACTION NO. 1:19-00582-KD-N ) FORD MOTOR COMPANY, ) Defendant. ) REPORT AND RECOMMENDATION This action is before the Court on the motion to remand under 28 U.S.C. § 1447(c) (Doc. 10) filed by the Plaintiff, Sam Krikorian. The assigned District Judge has referred the motion to the undersigned Magistrate Judge for appropriate action under 28 U.S.C. § 636(a)-(b), Federal Rule of Civil Procedure 72, and S.D. Ala. GenLR 72(a). See S.D. Ala. GenLR 72(b); (9/5/2019 electronic reference). In accordance with the Court’s briefing schedule (see Doc. 11), the Defendant, Ford Motor Company (“Ford”), timely filed a response (Doc. 12) in opposition to the motion, and Krikorian timely filed a reply (Doc. 13) to the response. The motion is now under submission (see Doc. 11). Upon consideration, the undersigned will, pursuant to § 636(b)(1)(B)-(C) and Rule 72(b)(1), recommend that the Court deny Krikorian’s motion to remand (Doc. 10) for the reasons explained herein. I. Procedural Background Krikorian commenced this case on July 26, 2019, by filing a five-count complaint in the Circuit Court of Baldwin County, Alabama (see Doc. 1 at 14 – 74), alleging causes of action against Ford for fraud (Count One), fraud in the inducement (Count Two), breaches of express warranty (Count Three) and implied warranty (Count Four), and violations of the Magnuson-Moss Warranty Act, 15 U.S.C. § 2301, et seq. (Count Five), arising from his purchase of an allegedly defective automobile manufactured by Ford. Ford removed Krikorian’s case to this Court under 28 U.S.C. § 1441(a) on August 27, 2019. See (Doc. 1). II. Analysis Where, as here, a case is removed from state court, “[t]he burden of establishing subject matter jurisdiction falls on the party invoking removal.” Univ. of S. Alabama v. Am. Tobacco Co., 168 F.3d 405, 411–12 (11th Cir. 1999). Accord, e.g., City of Vestavia Hills v. Gen. Fid. Ins. Co., 676 F.3d 1310, 1313 (11th Cir. 2012) (“The removing party bears the burden of proof regarding the existence of federal subject matter jurisdiction.”). Ford alleges diversity of citizenship under 28 U.S.C. § 1332(a) as the sole basis for this Court’s original jurisdiction. See 28 U.S.C. § 1446(a) (“A defendant or defendants desiring to remove any civil action from a State court shall file in the district court of the United States for the district and division within which such action is pending a notice of removal…containing a short and plain statement of the grounds for removal…”).1 “Diversity jurisdiction requires complete diversity; every plaintiff must be diverse from every defendant.” Triggs v. John Crump Toyota, Inc., 154 F.3d 1284, 1287 (11th Cir. 1998). Thus, a “ ‘party removing a case to federal court based on

1 Ford does not allege that jurisdiction can also be based on the Magnuson-Moss Warranty Act. Regardless, the Act contains a $50,000 amount in controversy jurisdictional provision, 15 U.S.C. § 2310(d)(3)(B), that Ford is unlikely to satisfy, as Krikorian only paid approximately $27,714.60 for the vehicle at issue, and neither attorneys’ fees nor “damages flowing from any pendent state law claim” can be used to calculate that amount in controversy. See Ansari v. Bella Auto. Grp., Inc., 145 F.3d 1270, 1272 (11th Cir. 1998) (per curiam). Punitive damages are also not available for a Magnuson-Moss claim brought in Alabama. See infra, n. 10. diversity of citizenship bears the burden of establishing the citizenship of the parties.’ ” Purchasing Power, LLC v. Bluestem Brands, Inc., 851 F.3d 1218, 1225 (11th Cir. 2017) (quoting Rolling Greens MHP, L.P. v. Comcast SCH Holdings L.L.C., 374 F.3d 1020, 1022 (11th Cir. 2004) (per curiam)). See also, e.g., Ray v. Bird & Son & Asset Realization Co., Inc., 519 F.2d 1081, 1082 (5th Cir. 1975) (“The burden of pleading diversity of citizenship is upon the party invoking federal jurisdiction . . .” (citing Mas v. Perry, 489 F.2d 1396 (5th Cir. 1974)).2 Diversity jurisdiction also requires that “the matter in controversy exceed[] the sum or value of $75,000, exclusive of interest and costs.” 28 U.S.C. § 1332(a); Underwriters at Lloyd's, London v. Osting-Schwinn, 613 F.3d 1079, 1085 & n.4 (11th Cir. 2010). Ford has sufficiently alleged, and Krikorian does not dispute, that the parties are diverse.3 However, Krikorian does assert that Ford cannot sufficiently prove that the requisite minimum amount in controversy is satisfied.

2 On “October 1, 1981 pursuant to the Fifth Circuit Court of Appeals Reorganization Act of 1980, P.L. 96-452, 94 Stat. 1995, … the United States Court of Appeals for the Fifth Circuit was divided into two circuits, the Eleventh and the ‘new Fifth.’ ” Bonner v. City of Prichard, Ala., 661 F.2d 1206, 1207 (11th Cir. 1981) (en banc). “The Eleventh Circuit, in the en banc decision Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir.1981), adopted as precedent decisions of the former Fifth Circuit rendered prior to October 1, 1981.” Smith v. Shook, 237 F.3d 1322, 1325 n.1 (11th Cir. 2001) (per curiam). 3 Ford’s notice of removal alleges that Krikorian, a natural person, is a citizen of, Alabama, see (Doc. 1 at 5); Taylor v. Appleton, 30 F.3d 1365, 1367 (11th Cir. 1994) (“Citizenship, not residence, is the key fact that must be alleged . . . to establish diversity for a natural person.”), and that Ford, a corporation, is a citizen of Delaware, the state under whose laws it was incorporated, and Michigan, the state where it has its principal place of business. See (Doc. 1 at 5); 28 U.S.C. § 1332(c)(1). While Krikorian also sues fictitious defendants, their citizenships are disregarded in determining whether removal under § 1332(a) is proper. See 28 U.S.C. § 1441(b)(1). Krikorian “does not dispute the diversity of citizenship” (Doc. 10 at 3), and the undersigned finds no reason at present to question Ford’s allegations of citizenship sua sponte. See Univ. of S. Ala. v. Am.

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Krikorian v. Ford Motor Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/krikorian-v-ford-motor-company-alsd-2019.