Morton v. Audi of America, LLC

CourtDistrict Court, N.D. Georgia
DecidedJanuary 24, 2024
Docket1:23-cv-04420
StatusUnknown

This text of Morton v. Audi of America, LLC (Morton v. Audi of America, LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Morton v. Audi of America, LLC, (N.D. Ga. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION DOUGLAS GRANT MORTON, Plaintiff, v. CIVIL ACTION FILE NO. 1:23-CV-4420-TWT AUDI OF AMERICA, LLC, et al., Defendants. OPINION AND ORDER This is a personal injury and products liability action. It is before the Court on a plethora of motions by the parties, including the Defendant Volkswagen Group of America, Inc.’s Motion for Reconsideration [Doc. 12], Volkswagen Group of America’s Motion to Transfer Venue [Doc. 18], the Defendants Asbury Automotive Group, Inc., FNK North America, Inc., Faurecia Automotive Seating, LLC, and Faurecia USA Holdings Inc.’s Motions

for Joinder of Volkswagen Group of America’s Motion to Transfer Venue [Docs. 19, 21], the Plaintiff’s Motion to Remand [Doc. 24], and the Defendants Grammer Industries, LLC, Grammer, Inc., and Brose North America, Inc.’s Motions to Dismiss for Lack of Personal Jurisdiction [Docs. 26, 38]. For the reasons set forth below, the Plaintiff’s Motion to Remand [Doc. 24] is DENIED; the Defendant Volkswagen Group of America’s Motion to Transfer Venue [Doc.

18] is GRANTED; and the remaining Motions [Docs. 12, 19, 21, 26, 38] are DENIED as moot. I. Background This case arises from the catastrophic injuries that the Plaintiff Douglas Grant Morton sustained during a car accident on September 25, 2021, when

he was rear ended by a truck while driving a 2020 Audi A6 in Marshall, North Carolina. (Am. Compl. ¶ 1). Although Morton was wearing a seatbelt, the car’s driver seat head restraint broke and failed to contain him during the collision, allowing his head and body to move back over the seat and leaving him paralyzed from the chest down. ( ¶¶ 48, 52). He alleges that the car’s defective driver seat occupant restraint system and head restraint proximately

caused his injuries. ( ¶ 53). The Plaintiff originally filed suit in Gwinnett County State Court on May 31, 2023, against Audi of America, LLC, Audi AG, Volkswagen Group of America, Inc., Volkswagen AG, and Asbury Automotive Group, Inc., the latter of which owns the Georgia-based dealership that sold the Audi vehicle involved in the incident. (Compl. ¶ 56). On August 17, 2023, the Plaintiff filed an Amended Complaint naming additional Defendants in the case after receiving

information from Audi regarding the seat component suppliers, including the Defendant Lear Corporation who supplied the driver’s seat. (Am. Compl. ¶ 59). On September 5 and 29, 2023, respectively, the Gwinnett County State Court denied Asbury’s Motion to Compel Arbitration and Volkswagen’s Motion to Dismiss for Forum Non Conveniens. (Docs. 24-2, 24-3). Lear removed the case

2 to this Court on September 28, 2023. The Plaintiff now moves to remand the case to the Gwinnett County State Court, and several Defendants seek transfer of the case to the Western District of North Carolina.

II. Legal Standard Federal courts are courts of limited jurisdiction; they may only hear cases that the Constitution and Congress have authorized them to hear. , 511 U.S. 375, 377 (1994). An action originally brought in state court may be removed by a defendant to federal court when the action satisfies the constitutional and statutory requirements

for original federal jurisdiction. 28 U.S.C. § 1441. Because of the limited authority of federal courts, “removal statutes are construed narrowly; where plaintiff and defendant clash about jurisdiction, uncertainties are resolved in favor of remand.” , 31 F.3d 1092, 1095 (11th Cir. 1994). When no federal question exists, diversity jurisdiction can be invoked under 28 U.S.C. 1332(a) where complete diversity exists among the parties and the amount in controversy exceeds $75,000. “[I]n removal cases, the burden is

on the party who sought removal to demonstrate that federal jurisdiction exists.” , 243 F.3d 1277, 1281 n.5 (11th Cir. 2001). “For the convenience of parties and witnesses, in the interest of justice, a district court may transfer any civil action to any other district or division

3 where it might have been brought or to any district or division to which all parties have consented.” 28 U.S.C. § 1404(a). A court should consider the following factors in evaluating a motion to transfer under § 1404(a):

(1) the convenience of the witnesses; (2) the location of relevant documents and the relative ease of access to sources of proof; (3) the convenience of the parties; (4) the locus of operative facts; (5) the availability of process to compel the attendance of unwilling witnesses; (6) the relative means of the parties; (7) a forum’s familiarity with the governing law; (8) the weight accorded a plaintiff’s choice of forum; and (9) trial efficiency and the interests of justice, based on the totality of the circumstances.

, 430 F.3d 1132, 1135 n.1 (11th Cir. 2005). “In a motion to transfer under § 1404(a), the burden is on [the defendant] to show that the balance of conveniences weighs in favor of the transfer.” , 161 F. Supp. 3d 1272, 1280 (N.D. Ga. 2015). III. Discussion Because the Plaintiff’s Motion to Remand implicates the Court’s subject matter jurisdiction, the Court considers that motion first. , 168 F.3d 405, 411 (11th Cir. 1999). The Court then considers the Defendant Volkswagen Group of America’s Motion to Transfer Venue before turning to the merits of the case implicated by the Defendants’ Motions for Reconsideration and to Dismiss for Lack of Personal Jurisdiction. A. Remand The issue of remand turns on whether the Defendant Asbury, a Georgia resident, was fraudulently joined in the case to defeat this Court’s diversity 4 jurisdiction. The Plaintiff contends that he states a viable claim against Asbury and therefore that the case should be remanded under the forum defendant rule, 28 U.S.C. § 1441(b)(2). (Br. in Supp. of Pl.’s Mot. to Remand, at 1–4). In

response, the Defendant Lear argues that remand is improper because the Plaintiff cannot state a claim against Asbury and thus fraudulently joined it to defeat diversity. (Def.’s Resp. Br. in Opp’n to Pl.’s Mot. to Remand, at 1–4). When “on the face of the pleadings, there is a lack of complete diversity which would preclude removal of the case to federal court,” the case “may nevertheless be removable if the joinder of the non-diverse party . . . [was]

fraudulent.” , 154 F.3d 1284, 1287 (11th Cir. 1998). Joinder of a non-diverse party may be fraudulent “when there is no possibility that the plaintiff can prove a cause of action against the resident (non-diverse) defendant.” To assess whether a plaintiff may establish a claim against a non-diverse defendant, the court must evaluate factual allegations in the light most favorable to the plaintiff.

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Morton v. Audi of America, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/morton-v-audi-of-america-llc-gand-2024.