Maadanian v. Mercedes-Benz USA LLC

Opinion

5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE 7 8 SEYYED JAVAD MAADANIAN, et al., Cause No. C22-0665RSL

9 Plaintiffs, ORDER GRANTING 10 v. DEFENDANTS’ MOTION FOR RECONSIDERATION 11 MERCEDES-BENZ USA, LLC., et al., 12 Defendants. 13

14 On May 5, 2023, the Court applied the federal common law doctrine of pendent personal 15 jurisdiction to hear claims for which there was no independent basis of personal jurisdiction – 16 17 namely the out-of-state plaintiffs’ state law claims – on the ground that they arise out of a 18 common nucleus of operative facts with a federal claim for which there was nationwide personal 19 jurisdiction. The Court specifically noted that problems related to the exercise of pendant party 20 21 jurisdiction were not an issue because the Court had jurisdiction over the out-of-state plaintiffs’ 22 federal claim. Dkt. # 61 at 9 n.5. The decision was without prejudice to defendants filing a 23 motion for reconsideration if jurisdictional contacts for a claim brought under the Magnuson- 24 25 Moss Warranty Act (“MMWA”) must be considered on a state-by-state, rather than a 26 nationwide, basis. Dkt. # 61 at 10 n.6. Defendants timely filed a motion for reconsideration. 27 28 1 Having reviewed the submissions of the parties, the Court finds that reconsideration is 2 appropriate. Each named plaintiff in a class action must demonstrate the Court’s power to decide 3 the claims he or she has asserted. Dkt. # 61 at 6. For the reasons stated in the Court’s “Order 4 5 Denying Defendants’ Motion to Dismiss,” the only way the Court would have pendent 6 jurisdiction over the out-of-state plaintiffs’ state law claims would be if the Court had 7 jurisdiction over their federal MMWA claims.1 Jurisdiction over the MMWA claim turned on 8 9 the proposition that the Court could consider defendants’ contacts with the United States as a 10 whole, in which case it could be said that the out-of-state plaintiffs’ MMWA claims arose out of 11 or relate to defendants’ nationwide forum-related activities. 12 13 Having now conceded that the MMWA claim does not authorize nationwide personal 14 jurisdiction, the out-of-state plaintiffs cannot show that any of their claims – state or federal – 15 arise from defendants’ contacts in Washington. The similarity of their claims with those asserted 16 17 by Maadanian is an insufficient hook on which to exercise jurisdiction over claims which arose 18 entirely outside the forum and which will stand or fall with the express and implied warranty 19 claims asserted under their other states’ laws. Dkt. # 61 at 10.2 20 21 22 1 Plaintiffs have not argued that the Court should or could exercise pendent party jurisdiction. 23 2 The Court respectfully disagrees with the decision in Ashton v. J.M. Smucker Co., 2020 WL 24 8575140, at *8 (C.D. Cal. Dec. 16, 2020), which ignores important language from Action Embroidery 25 Corp. v. Atl. Embroidery, Inc., 368 F.3d 1174, 1180 (9th Cir. 2004), and exercises pendent party jurisdiction without acknowledging it. Most of the other cases cited by plaintiffs pre-date Bristol-Myers 26 Squibb Co. v. Superior Court of Cal., San Francisco County, 582 U.S. 255 (2017), which highlighted the need to ensure that each plaintiff’s claims arose from defendant’s contacts with the forum, a 27 constitutional requirement which considerations of efficiency and economy cannot override. 28 1 For all of the foregoing reasons, defendants’ motion for reconsideration (Dkt. # 64) is 2 GRANTED. The claims of the out-of-state plaintiffs are DISMISSED. 3

4 5 Dated this 14th day of July, 2023.

7 Robert S. Lasnik 8 United States District Judge

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