Lu Wang v. FCA US LLC

CourtDistrict Court, C.D. California
DecidedApril 28, 2025
Docket8:24-cv-02060
StatusUnknown

This text of Lu Wang v. FCA US LLC (Lu Wang 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
Lu Wang v. FCA US LLC, (C.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE CENTRAL DISTRICT OF CALIFORNIA 10 11 LU WANG and Case No. 8:24-cv-02060-JWH-KES YONG CHENG, 12 Plaintiffs, ORDER DENYING PLAINTIFFS’ 13 MOTION TO REMAND [ECF v. No. 15] 14 FCA US LLC, and 15 DOES 1-10, inclusive,

16 Defendants.

17 18 19 20 21 22 23 24 25 26 27 1 Before the Court is the motion of Plaintiffs Lu Wang and Yong Cheng to 2 remand this case to Orange County Superior Court.1 The Court concludes that 3 this matter is appropriate for resolution without a hearing. See 4 Fed. R. Civ. P. 78; L.R. 7-15. After considering the papers filed in support and in 5 opposition,2 the Court DENIES Plaintiffs’ Motion. 6 I. BACKGROUND 7 Plaintiffs commenced this action in Orange County Superior Court in 8 August 2024.3 In their Complaint, Plaintiffs assert five claims against Defendant 9 FCA US LLC based upon violations of the Song-Beverly Consumer Warranty 10 Act.4 11 FCA removed this action to this Court in September 2024 on the basis of 12 diversity jurisdiction.5 Plaintiffs filed the instant Motion in November 2024.6 In 13 their Motion, Plaintiffs assert that FCA cannot establish diversity jurisdiction 14 because FCA cannot satisfy its burden to show that the amount in controversy in 15 this matter exceeds $75,000.7 Plaintiffs did not, however, concede that they 16

17 1 Pls.’ Mot. to Remand (the “Motion”) [ECF No. 15]. 18 2 The Court considered the documents of record in this action, including 19 the following papers: (1) Notice of Removal (including its attachments) [ECF No. 1]; (2) Compl. (the “Complaint”) [ECF No. 1-1]; (3) Motion; (4) Def.’s 20 Opp’n to the Motion (the “Opposition”) [ECF No. 16]; (5) Pl.’s Reply in Supp. 21 of the Motion (the “Reply”) [ECF No. 17]; (6) Pl.’s Suppl. Briefing in Supp. of the Motion (the “Supplemental Brief in Support”) [ECF No. 20]; and 22 (6) Def.’s Suppl. Opp’s to the Motion (the “Supplemental Opposition”) [ECF 23 No. 21]. 24 3 See Complaint. 25 4 See generally id. 26 5 See Notice of Removal. 27 6 See Motion. 1 seek a monetary judgment of $75,000 or less.8 Therefore, on its own motion, 2 the Court granted FCA leave to engage in jurisdictional discovery and ordered 3 the parties to submit supplemental briefing on the amount in controversy.9 4 II. LEGAL STANDARD 5 Federal courts are courts of limited jurisdiction. Accordingly, “[t]hey 6 possess only that power authorized by Constitution and statute.” Kokkonen v. 7 Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994). In every federal case, the 8 basis for federal jurisdiction must appear affirmatively from the record. See 9 DaimlerChrysler Corp. v. Cuno, 547 U.S. 332, 342 n.3 (2006). “The right of 10 removal is entirely a creature of statute and a suit commenced in a state court 11 must remain there until cause is shown for its transfer under some act of 12 Congress.” Syngenta Crop Prot., Inc. v. Henson, 537 U.S. 28, 32 (2002) (internal 13 quotation marks omitted). When Congress has acted to create a right of 14 removal, those statutes, unless otherwise stated, are strictly construed against 15 removal jurisdiction. See id. 16 To remove an action to federal court under 28 U.S.C. § 1441, the 17 removing defendant “must demonstrate that original subject-matter jurisdiction 18 lies in the federal courts.” Syngenta, 537 U.S. at 33. As such, a defendant may 19 remove civil actions in which either (1) a federal question exists; or (2) complete 20 diversity of citizenship between the parties exists and the amount in controversy 21 exceeds $75,000. See 28 U.S.C. §§ 1331 & 1332. “Complete diversity” means 22 that “each defendant must be a citizen of a different state from each plaintiff.” 23 In re Digimarc Corp. Derivative Litigation, 549 F.3d 1223, 1234 (9th Cir. 2008). 24 25

26 8 See id. 27 9 See Order Regarding Pl.’s Mot. to Remand (the “Jurisdictional Discovery 1 The right to remove is not absolute, even when original jurisdiction exists. 2 In other words, the removing defendant bears the burden of establishing that 3 removal is proper. See Abrego Abrego v. Dow Chem. Co., 443 F.3d 676, 684 (9th 4 Cir. 2006) (noting the “longstanding, near-canonical rule that the burden on 5 removal rests with the removing defendant”); Gaus v. Miles, Inc., 980 F.2d 564, 6 566 (9th Cir. 1992) (“[t]he strong presumption against removal jurisdiction 7 means that the defendant always has the burden of establishing that removal is 8 proper” (quotation marks omitted)). Any doubts regarding the existence of 9 subject matter jurisdiction must be resolved in favor of remand. See id. 10 (“[f]ederal jurisdiction must be rejected if there is any doubt as to the right of 11 removal in the first instance”). 12 III. ANALYSIS 13 Based upon its jurisdictional discovery, FCA estimates that Plaintiffs seek 14 at least $51,278.67 in restitution, based upon the price of the vehicle less a rebate 15 and reasonable allowance, as well as $102,557.34 in civil penalties.10 Plaintiffs 16 also seek attorneys’ fees, prejudgment interest, and punitive damages.11 17 Plaintiffs do not contest that the vehicle is valued at roughly $64,000, nor 18 that they seek civil penalties, attorneys’ fees, prejudgment interest, and punitive 19 damages.12 Nevertheless, Plaintiffs maintain that FCA has not met its burden to 20 establish that the amount in controversy exceeds $75,000.13 According to 21 Plaintiffs, FCA’s estimates are speculative because civil penalties and 22 prospective attorneys’ fees may not be included in the amount in controversy.14 23

24 10 See Supplemental Opposition 2:17-19 & 3:2-4. 25 11 See id. at 2:6-9. 26 12 See generally Supplemental Brief in Support. 27 13 See id. 1 Plaintiffs’ arguments border on frivolous. The Ninth Circuit routinely 2 considers civil penalties when deciding whether the amount-in-controversy 3 requirement has been satisfied, including in Song-Beverly cases. See, e.g., 4 Babasa v. LensCrafters, Inc., 498 F.3d 972, 974 (9th Cir. 2007); see also Morey v. 5 Louis Vuitton North Am., Inc., 561 F. App’x 642, 643 (9th Cir. 2011) (including 6 Song-Beverly civil penalties in amount-in-controversy calculation). The Ninth 7 Circuit has also held repeatedly that attorneys’ fees may “be included in the 8 amount in controversy if they are available to prevailing plaintiffs pursuant to 9 state fee-shifting statutes.” Shoner v. Carrier Corp., 30 F.4th 1144, 1148 (9th Cir. 10 2022). The Song-Beverly Act permits a successful plaintiff to recover 11 reasonable attorneys’ fees, so attorneys’ fees must be included when calculating 12 the amount in controversy here. See Cal. Civ. Code § 1794(d).

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Related

Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
Syngenta Crop Protection, Inc. v. Henson
537 U.S. 28 (Supreme Court, 2002)
DaimlerChrysler Corp. v. Cuno
547 U.S. 332 (Supreme Court, 2006)
Babasa v. LensCrafters, Inc.
498 F.3d 972 (Ninth Circuit, 2007)
In Re Digimarc Corp. Derivative Litigation
549 F.3d 1223 (Ninth Circuit, 2008)
Elsa Chavez v. Jpmorgan Chase Bank
888 F.3d 413 (Ninth Circuit, 2018)
Nicholas Shoner v. Carrier Corporation
30 F.4th 1144 (Ninth Circuit, 2022)

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Bluebook (online)
Lu Wang v. FCA US LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lu-wang-v-fca-us-llc-cacd-2025.