Maxwell v. E-Z-Go, A Division of Textron, Inc.

843 F. Supp. 2d 1209, 2012 WL 516952, 2012 U.S. Dist. LEXIS 19502
CourtDistrict Court, M.D. Alabama
DecidedFebruary 16, 2012
DocketCase No. 2:11-cv-639-MEF
StatusPublished

This text of 843 F. Supp. 2d 1209 (Maxwell v. E-Z-Go, A Division of Textron, Inc.) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Maxwell v. E-Z-Go, A Division of Textron, Inc., 843 F. Supp. 2d 1209, 2012 WL 516952, 2012 U.S. Dist. LEXIS 19502 (M.D. Ala. 2012).

Opinion

MEMORANDUM OPINION AND ORDER

MARK E. FULLER, District Judge.

This cause is before the Court on an August 10, 2011 Notice of Removal (Doc. # 1) filed by Defendants E-Z-Go Division of Textron, Inc. (“E-Z-Go”) and Textron, Inc. (“Textron”) (collectively “the removing Defendants”), and a Motion to Remand (Doc. # 3) filed by Plaintiff Thomas Maxwell. The issues having been fully briefed, and after careful consideration of the law and the arguments of counsel, the court finds that Plaintiffs’ motion to remand is due to be GRANTED.

I. BACKGROUND

On September 22, 2010, Plaintiff filed suit against E-Z-Go, Textron, Defendant [1212]*1212Carts and Buggies, LLC (“Carts & Buggies”), and Defendant Robert Maxwell. The Complaint (Doc. # 1-1) alleges that Lawrence K. Maxwell (the “Deceased”) was driving an E-Z-Go cart (“the Vehicle”) allegedly designed, manufactured, and placed into the stream of commerce by E-Z-Go and Textron. (Compl. ¶ 15.) The Complaint further alleges that Defendant Carts & Buggies sold the Vehicle to the Deceased, as well as a lift kit, which was installed by Defendant Robert Maxwell. As the Deceased ascended a hill, the engine stalled, causing the Vehicle to roll backward and overturn, landing on top of and killing the Deceased.

Plaintiff brings wrongful death claims against all Defendants, as well as a claim under the Alabama Extended Manufacturer’s Liability Doctrine (“AEMLD”) against Defendants E-Z-Go, Textron, and Carts & Buggies. As to Robert Maxwell, the Complaint alleges that he “undertook or assumed a duty to select a lift kit to modify the right height of the Subject Vehicle[,]” and that he “breached that duty” by “selecting] a lift kit not suitable for the Subject Vehicle and [by] failing] to follow installation instructions.” (Compl. ¶¶ 43-45.)

In the Notice of Removal, Defendants E-Z-Go and Textron allege that Plaintiff is a citizen of Alabama for purposes of diversity jurisdiction. See 28 U.S.C. § 1332(c)(2) (a personal representative is a citizen of the state of which the deceased was a citizen at the time of the deceased’s death). Textron and E-Z-Go are alleged to be citizens of Rhode Island and Georgia, respectively. And although Carts & Buggies and Robert Maxwell are citizens of Alabama, Textron and E-Z-Go contend that their citizenship should be disregarded for purposes of diversity jurisdiction because they are fraudulently joined.

On August 25, 2011, within thirty days of removal, 28 U.S.C. § 1447(c), Plaintiff filed his motion to remand, alleging that the removal is both procedurally defective and that subject matter jurisdiction does not exist as a substantive matter.1

II. STANDARD OF REVIEW

“[F]ederal courts have a strict duty to exercise the jurisdiction that is conferred upon them by Congress.” Quackenbush v. Allstate Ins. Co., 517 U.S. 706, 716, 116 S.Ct. 1712, 135 L.Ed.2d 1 (1996). However, “[fjederal courts are courts of limited jurisdiction.” Burns v. Windsor Ins. Co., 31 F.3d 1092, 1095 (11th Cir.1994); see also Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 114 S.Ct. 1673, 128 L.Ed.2d 391 (1994). Thus, with respect to cases removed to this Court pursuant to 28 U.S.C. § 1441, the law of the Eleventh Circuit favors remand where federal jurisdiction is not absolutely clear. “[R]emoval statutes are construed narrowly; where plaintiff and defendant clash about jurisdiction, uncertainties are resolved in favor of remand.” Burns, 31 F.3d at 1095. “In evaluating a motion to remand, the removing party bears the burden of demonstrating federal jurisdiction.” Triggs v. John Crump Toyota, Inc., 154 F.3d 1284, 1287 n. 4 (11th Cir.1998) (citing Pacheco de Perez v. AT & T Co., 139 F.3d 1368, 1373 (11th Cir.1998)).

Even if “on the face of the pleadings, there is a lack of complete diversity, an action may nevertheless be removable if the joinder of the non-diverse party ... [was] fraudulent.” Triggs, 154 F.3d at 1287 (citing Tapscott v. MS Dealer Service [1213]*1213Corp., 77 F.3d 1353, 1355 (11th Cir.1996)). “Fraudulent joinder is a judicially created doctrine that provides an exception to the requirement of complete diversity.” Id. The courts have recognized three situations in which joinder may be deemed fraudulent: (1) when there is no reasonable possibility that the plaintiff can prove a cause of action against the resident (non-diverse) defendant; (2) when there is outright fraud in the plaintiffs pleading of jurisdictional facts; and (3) when there is no real connection to the claim and the resident (non-diverse) defendant. Id.; see also Legg v. Wyeth, 428 F.3d 1317, 1325 (11th Cir.2005). The burden of establishing fraudulent joinder is a “heavy one.” Crowe v. Coleman, 113 F.3d 1536, 1538 (11th Cir.1997).

As to the first type of fraudulent joinder, “[t]he plaintiff need not have a winning case against the allegedly fraudulent defendant; he need only have a [reasonable ] possibility of stating a valid cause of action in order for the joinder to be legitimate.” Triggs, 154 F.3d at 1287; see also Legg 428 F.3d at 1325 n. 5 (stating that the “potential for legal liability must be reasonable, not merely theoretical” (internal quotation marks omitted)).

“The determination of whether a resident defendant has been fraudulently joined must be based upon the plaintiffs pleadings at the time of removal, supplemented by any affidavits and deposition transcripts submitted by the parties.” Legg, 428 F.3d at 1322 (quoting Pacheco de Perez, 139 F.3d at 1380). “The proceeding appropriate ‘for resolving a claim of fraudulent joinder is similar to that used for ruling on a motion for summary judgment under [Federal Rule of Civil Procedure 56].’ ” Id. at 1322-23 (quoting Crowe v. Coleman, 113 F.3d 1536, 1538 (11th Cir. 1997)). Accordingly, all contested issues of substantive fact and any uncertainties as to the current state of the law must be resolved in the plaintiffs favor. See id. at 1323; see also Cabalceta v. Standard Fruit Co., 883 F.2d 1553, 1561 (11th Cir.1989).

III. DISCUSSION

A. Plaintiff’s Contentions that the Removal is Procedurally Defective

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Bluebook (online)
843 F. Supp. 2d 1209, 2012 WL 516952, 2012 U.S. Dist. LEXIS 19502, Counsel Stack Legal Research, https://law.counselstack.com/opinion/maxwell-v-e-z-go-a-division-of-textron-inc-almd-2012.