Mendoza v. Hyundai Motor Company, LTD

District Court, N.D. California·Decided January 17, 2024·No. 5:15-cv-01685·Unknown

Opinion

ELIZABETH MENDOZA, et al., Case No. 15-cv-01685-BLF

Plaintiffs, ORDER DENYING MOTION TO v. CLARIFY

HYUNDAI MOTOR COMPANY, LTD, et [Re: ECF No. 122] al., Defendants. Knight Motors, LP, Doman Auto & Marine Sales, Inc., and Christopher D. Pantelis (collectively “Knight Motors”) submitted a motion to clarify the Court’s order granting in part and denying in part Defendant Hyundai Motor America, Inc.’s motion for a permanent injunction under the All Writs Act. ECF No. 122. Hyundai opposes the motion. ECF No. 123. For the reasons stated below, the Court DENIES the motion. The facts of this case are more thoroughly laid out in the Court’s order granting in part and denying in part Hyundai’s motion for a permanent injunction under the All Writs Act. See ECF No. 121 at 1–4. Accordingly, the Court will provide only an abbreviated summary here. In August 2019, Hyundai filed an action against Knight Motors in the Court of Common Pleas of Allegheny County, Pennsylvania. See ECF No. 104-15. Hyundai’s operative complaint alleges that Knight Motors engaged in a fraudulent scheme to exploit Hyundai’s extended warranty on 2011 to 2014 Hyundai Sonatas. ECF No. 99-9 ¶ 9. Knight Motors counterclaimed, alleging Hyundai refused to accept Knight Motors’ submissions of 2011 to 2014 Sonatas and that Hyundai engaged in conduct designed to avoid its obligations under the Class Action Settlement Hyundai filed a motion in this Court, seeking to enjoin Knight Motors’ counterclaims from being brought in state court. See ECF No. 99. On January 2, 2024, the Court granted in part and denied in part Hyundai’s motion. ECF No. 121. The Court found that Counts I through V of Knight Motors’ counterclaims—which brought claims for “fraud, breach of contract, anticipatory repudiation/breach of contract, intentional interference with prospective contracts/relations, and third-party beneficiary”—required the state court to interpret or enforce the Settlement Agreement or would require the state court to do so in order to dispose of the claims. Id. at 14. The Court held that because this Court retained continuing and exclusive jurisdiction to construe, enforce, and administer the Settlement Agreement, the “necessary in aid of jurisdiction” exception to the Anti-Injunction Act applied and an injunction under the All Writs Act was appropriate. Id. at 7– 11. Therefore, the Court enjoined Knight Motors from bringing Counts I through V of its counterclaims in the state court action. Id. at 16. On January 3, 2024, Knight Motors filed a motion to conform pleadings to the evidence in the Pennsylvania state court, seeking to amend Counts IV and V1 to raise claims that did not require the construction, enforcement, or administration of the Settlement Agreement. ECF No. 122-2. Knight Motors has not filed an amended counterclaim regarding Counts IV and V. Under Federal Rule of Civil Procedure 60, a court may “correct a clerical mistake or a mistake arising from oversight or omission whenever one is found in a judgment, order, or other part of the record.” Fed. R. Civ. P. 60(a). “[T]he clarification process presumes some legitimate need supporting relief, such as the existence of ambiguity or confusion that can be corrected with further explanation.” Optronic Techs., Inc. v. Ningbo Sunny Elec. Co., Ltd., No. 16-cv-06370, 2020 WL 3892869, at *1 (N.D. Cal. July 10, 2020) (quoting Padgett v. Loventhal, No. 04-cv- 03946, 2015 WL 13753300, at *1 (N.D. Cal. May 13, 2015)) (alteration in original). The Local

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