Perkins v. Mercedes-Benz USA, LLC

CourtDistrict Court, N.D. California
DecidedOctober 14, 2022
Docket3:22-cv-03540
StatusUnknown

This text of Perkins v. Mercedes-Benz USA, LLC (Perkins v. Mercedes-Benz USA, LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Perkins v. Mercedes-Benz USA, LLC, (N.D. Cal. 2022).

Opinion

1 2 3 4 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE NORTHERN DISTRICT OF CALIFORNIA 7 8 MITCHELL PERKINS, Case No. 22-cv-03540-CRB

9 Plaintiff,

ORDER GRANTING PLAINTIFF’S 10 v. MOTION TO REMAND AND DENYING AS MOOT 11 MERCEDES-BENZ USA, LLC, et al., DEFENDANTS’ MOTION TO DISMISS AND/OR STRIKE 12 Defendants.

13 Plaintiff Mitchell Perkins brings this action against Defendants Mercedes-Benz 14 USA, LLC (“MBUSA”) and Mercedes-Benz of Marin (“MB-Marin”) for breach of 15 implied and express warranties under California’s Song-Beverly Consumer Warranty Act 16 (“Song-Beverly”) and the federal Magnuson-Moss Act (“MMWA”), and for negligent 17 repair. See Compl. (dkt. 1-1, Ex. A).1 MBUSA removed the case to this Court, asserting 18 federal question jurisdiction. NOR (dkt. 1) ¶ 4. Perkins moves to remand. Pl.’s Mot. (dkt. 19 21-1). Defendants move to dismiss and/or strike portions of the complaint. Defs.’ Mot. 20 (dkt. 19). As explained below, Defendants have failed to establish that the amount in 21 controversy “more likely than not” meets the MMWA’s statutory minimum of $50,000. 22 Finding this case suitable for resolution without oral argument under Civil Local Rule 7- 23 1(b), the Court VACATES the hearing scheduled on October 21, 2022, GRANTS Perkins’ 24 motion to remand, and DENIES AS MOOT Defendants’ motion to dismiss. 25 26 27 I. BACKGROUND 1 A. Facts 2 On or about November 12, 2014, Perkins entered into a warranty contract for a 3 2014 Mercedes-Benz GLK 250 (the “Vehicle”) manufactured and distributed by MBUSA. 4 Compl. ¶ 10. Perkins first presented the Vehicle for repair in 2016 with 43,248 miles on 5 the odometer. Id. ¶ 17. Perkins alleges that MBUSA failed to conform the Vehicle to its 6 express and implied warranties after a reasonable number of repair attempts, in violation of 7 Song-Beverly and the MMWA. Id. ¶¶ 24, 32, 38, 43, 49, 46, 55, 61. Perkins further 8 alleges that MBUSA was fully aware of its inability to conform the Vehicle to applicable 9 express warranties, but willfully refused to provide materials to effect repair, replace the 10 Vehicle, or make restitution. Id. ¶¶ 34, 41, 44. Perkins also brings a claim of negligent 11 repair against MB-Marin, alleging “fail[ure] to properly store, prepare, and repair the 12 Subject Vehicle in accordance with industry standards.” Id. ¶ 66. 13 In the body of the complaint, Perkins alleges that he suffered damages “in a sum to 14 be proven at trial in an amount that is not less than $25,001.00.” Id. ¶ 29. In the prayer for 15 relief, Perkins asks for (among other things) “general, special and actual damages 16 according to proof,” “a civil penalty in the amount of two times Plaintiff’s actual damages 17 pursuant to” Song-Beverly, and “costs of the suit and Plaintiff’s reasonable attorneys’ fees 18 pursuant to” that Act. Id. at 10–11. 19 B. Procedure 20 MBUSA removed this case, asserting federal question jurisdiction because the 21 amount in controversy surpasses the MMWA’s jurisdictional threshold. NOR ¶¶ 4, 8. 22 Perkins moves to remand, arguing that MBUSA failed to establish unanimous 23 consent to removal and that the amount in controversy is less than the $50,000 required for 24 federal subject matter jurisdiction under the MMWA. Pl.’s Mot. at 1. Defendants move to 25 dismiss and/or strike portions of the complaint pursuant to Rules 12(b)(1), 12(b)(6), and 26 12(f) of the Federal Rules of Civil Procedure. Defs.’ Mot. at 1. Because the Court 27 remands this case, it does not reach Defendants’ motion to dismiss. II. LEGAL STANDARD 1 A defendant may remove “any civil action brought in a State court of which the 2 district courts . . . have original jurisdiction.” 28 U.S.C. § 1441(a). District courts have 3 federal question jurisdiction over civil actions that “aris[e] under the Constitution, laws, or 4 treaties of the United States.” Id. § 1331. There is a “strong presumption” against removal 5 jurisdiction, and courts “strictly construe the removal statute against removal.” Gaus v. 6 Miles, Inc., 980 F.2d 564, 566 (9th Cir. 1992). This “means that the defendant always has 7 the burden of establishing that removal is proper.” Hunter v. Philip Morris USA, 582 F.3d 8 1039, 1042 (9th Cir. 2009) (citation and internal quotation marks omitted). Any doubt 9 regarding the legitimacy of the removal favors remanding the case to state court. Id. 10 III. DISCUSSION 11 Perkins seeks remand on two grounds. First, he argues that removal was 12 procedurally improper because MBUSA has not established that MB-Marin also consented 13 to removal, as required by 28 U.S.C. § 1441(b). See Pl.’s Mot. at 1. Second, he argues 14 that the Court lacks subject matter jurisdiction because Defendants have not shown that the 15 amount in controversy exceeds the MMWA’s jurisdictional threshold. Id. 16 A. Consent 17 The Court rejects remand on the basis of lack of consent because Perkins’ 18 procedural challenge is untimely and therefore waived. Even if it were not waived, this 19 challenge fails because the Court can infer MB-Marin’s consent. 20 All properly joined and served defendants must “join in or consent to” removal in 21 cases involving multiple defendants. 28 U.S.C. § 1446(b)(2)(A); Hewitt v. City of 22 Stanton, 798 F.2d 1230, 1232 (9th Cir. 1986). Parties challenging removal “on the basis of 23 any defect other than lack of subject matter jurisdiction”—including consent—must file a 24 motion to remand within 30 days after a notice of removal is filed. 28 U.S.C. § 1447(c). 25 The consent requirement is met as long as the removing defendant “avers that all 26 defendants consent to removal” in their timely removal notice. Proctor v. Vishay 27 Intertechnology Inc., 584 F.3d 1208, 1225 (9th Cir. 2009); see id. (noting that sanctions 1 and the ability to object to removal mitigate concerns that a defendant will make a false 2 averment). Several district courts have held that “formal consent is unnecessary ‘where 3 the pleadings demonstrated defendants were all represented by the same counsel’” and 4 defendants jointly filed removal notices or oppositions to remand. See, e.g., Tanious v. 5 Gattoni, 533 F. Supp. 3d 770, 775 (N.D. Cal. 2021) (quoting Lewis v. City of Fresno, 627 6 F. Supp. 2d 1179, 1186 (E.D. Cal. 2008)). 7 Perkins’ consent-based challenge fails because it is untimely. MBUSA removed 8 this case to federal court on June 15, 2022. See NOR. However, Perkins did not file his 9 motion to remand until August 10, 2022, nearly 60 days after removal. See Pl.’s Mot. 10 Therefore, Perkins waived his consent-based challenge to removal because it came long 11 after the 30-day time limit in 28 U.S.C. § 1447(c). See, e.g., Vasquez v. N. Cnty. Transit 12 Dist., 292 F.3d 1049, 1060 n.5 (9th Cir. 2002) (noting that the plaintiff waived their 13 consent-based challenge by failing to move for remand within 30 days of removal). 14 Perkins’ consent-based challenge also fails because the Court can infer unanimous 15 consent. See Tanious, 533 F. Supp. 3d at 775.

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Perkins v. Mercedes-Benz USA, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/perkins-v-mercedes-benz-usa-llc-cand-2022.