Ricardo Quiroz v. FCA US LLC

CourtDistrict Court, C.D. California
DecidedNovember 29, 2023
Docket2:23-cv-06737
StatusUnknown

This text of Ricardo Quiroz v. FCA US LLC (Ricardo Quiroz v. FCA US LLC) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ricardo Quiroz v. FCA US LLC, (C.D. Cal. 2023).

Opinion

O 1

2 3 4 JS-6 5 6 7

8 United States District Court 9 Central District of California

11 RICARDO QUIROZ Case № 2:23-CV-06737-ODW (SSC)

12 Plaintiffs, ORDER REMANDING CASE 13 v.

14 FCA US LLC.,

15 Defendants.

16 17 I. INTRODUCTION 18 On August 21, 2023, the Court ordered Defendant FCA US LLC (“FCA”) to 19 show cause why this action should not be remanded for lack of diversity jurisdiction 20 due to an insufficient amount in controversy. (Order to Show Cause (“OSC”), ECF 21 No. 9.) On September 6, 2023, FCA filed a response to the Court’s Order to Show 22 Cause, (FCA Resp., ECF No. 10.), and on September 20, 2023, Plaintiff Ricardo 23 Quiroz filed a brief replying to FCA. (Quiroz Br., ECF No. 12.) Having reviewed 24 FCA’s Notice of Removal and both parties’ submissions to the Court’s Order to Show 25 Cause, the Court hereby REMANDS the action based on FCA’s failure to establish 26 that the amount in controversy exceeds $75,000.1 27

28 1 Having carefully considered the papers filed in connection with the Motion, the Court deemed the matter appropriate for decision without oral argument. Fed. R. Civ. P. 78; C.D. Cal. L.R. 7-15. 1 II. BACKGROUND 2 On May 28, 2020, Quiroz and FCA entered into a warranty contract regarding a 3 2018 Jeep Grand Cherokee (“the Subject Vehicle”) for a total price of $39,944.96. 4 (Notice of Removal Ex. B to Declaration of Scott S. Shepardson (“Compl.”), ¶ 15, 5 ECF No. 1-3.) The warranty contract “included bumper-to-bumper coverage for 6 defects in materials and workmanship for the earlier of 36 Months (3 Years) or 7 0 miles, a Drivetrain/Powertrain Warranty that covered defects in materials and 8 workmanship for the earlier of 60 Months (5 Years) or 0[sic], and California 9 Emissions Warranty that covered defects in materials and workmanship in emissions 10 parts for the earlier of 7 years or 70,000 miles.” (Id. ¶ 7.) Quiroz alleges that 11 sometime thereafter “[d]efects and nonconformities to warranty manifested 12 themselves within the applicable express warranty period” and that “[t]he 13 nonconformities substantially impaired the use, value and/or safety of the Subject 14 Vehicle.” (Id. ¶ 16.) Quiroz further alleges that FCA has failed “to remedy the 15 defects and nonconformities . . . or to promptly issue restitution in compliance with 16 the Song-Beverly Act.” (Id. ¶ 20.) 17 On June 30, 2023, Quiroz filed this action in Ventura County Superior Court. 18 (Notice of Removal (“NOR”) ¶ 12, ECF No. 1.) In the Complaint, Quiroz asserts two 19 causes of action: (1) breach of express warranty in violation of the Song-Beverly Act, 20 and (2) violation of the Song-Beverly Act Section 1793.2. (Compl. ¶¶ 14–37.) 21 Quiroz seeks relief in the form of monetary damages, any “cover” damages under 22 Commercial Code §§ 2711–2712, and Civil Code, § 1794, et seq., incidental and 23 consequential damages, and a civil penalty of up to two times the amount of actual 24 damages pursuant to the Song-Beverly Act. (Compl. ¶¶ 35–37.) On August 16, 2023, 25 FCA removed this case to federal court on the basis of diversity jurisdiction. (See 26 generally NOR.) The Court has ordered the parties to show cause why this action 27 should not be remanded for lack of diversity jurisdiction due to an insufficient amount 28 1 in controversy. (See generally OSC.) The parties have submitted their responses. 2 (See generally FCA Resp., Quiroz Br.) 3 LEGAL STANDARD 4 Federal courts have subject matter jurisdiction only as authorized by the 5 Constitution and Congress. U.S. Const. art. III, § 2, cl. 1; Kokkonen v. Guardian Life 6 Ins. Co. of Am., 511 U.S. 375, 377 (1994). A suit filed in a state court may be 7 removed to federal court if the federal court would have had original jurisdiction over 8 the suit. 28 U.S.C. § 1441(a). Federal district courts have original jurisdiction where 9 an action arises under federal law, or where each plaintiff’s citizenship is diverse from 10 each defendant’s citizenship and the amount in controversy exceeds $75,000, 11 exclusive of interest and costs. 28 U.S.C. § 1331, 1332(a). 12 There is a strong presumption that a court is without jurisdiction until 13 affirmatively proven otherwise. See Fifty Assocs. v. Prudential Ins. Co. of Am., 14 446 F.2d 1187, 1190 (9th Cir. 1970); Gaus v. Miles, Inc., 980 F.2d 564, 566 (9th Cir. 15 1992) (“Federal jurisdiction must be rejected if there is any doubt as to the right of 16 removal in the first instance.”). The removing party “bears the burden of showing, by 17 a preponderance of the evidence, that the amount in controversy exceeds the statutory 18 amount.” Lewis v Verizon Commc’ns, Inc., 627 F.3d 395, 397 (9th Cir. 2010). 19 III. DISCUSSION 20 FCA argues that the amount in controversy requirement is met because Quiroz’s 21 claims for actual damages, civil penalties, and attorneys’ fees, in total, are over 22 $75,000 in controversy. (See NOR ¶¶ 10–20.) Here, the amount in controversy is not 23 clearly ascertainable from the face of the complaint. (See generally Compl.) 24 Therefore, FCA bears the burden of proving the amount in controversy more likely 25 than not exceeds $75,000. 26 A. Actual Damages 27 Under the Song-Beverly Act, the buyer of a vehicle may recover “in an amount 28 equal to the actual price paid or payable by the buyer,” reduced by “that amount 1 directly attributable to use by the buyer.” Cal. Civ. Code § 1793.2(d)(2)(B)–(C). This 2 reduction, also known as a mileage offset, reduces the buyer’s recovery by an amount 3 directly proportional to the number of miles driven, with each mile driven reducing 4 the purchase price by 1/120,000. See id. § 1793.2(d)(2)(C). 5 Here, FCA and Quiroz agree that actual damages in controversy are $33,666.96, 6 based on a purchase price of $39,944.96 minus an offset of $6,278.00. (Decl. Scott 7 Shepardson ISO FCA Resp. (“Shepardson Decl. ISO FCA”) ¶ 10, ECF No. 10-1; 8 Quiroz Br. at 5.2) The parties' calculations appear proper under the Song-Beverly 9 damages framework for motor vehicles. 10 The Court therefore assumes for the purpose of this Order, without making any 11 legal or factual determinations, that the actual damages in controversy in this case are 12 $33,666.96. 13 B. Civil Penalties 14 Next, FCA argues that because the Prayer for Relief in Quiroz’s complaint 15 alleges that Quiroz is entitled to a civil penalty of up to two times his actual damages, 16 a potential civil penalty valued at $67,433.92 should be included in the amount in 17 controversy calculation. (Shepardson Decl. ISO FCA ¶ 11.) 18 The Song-Beverly Act states that “[i]f the buyer establishes that the failure to 19 comply was willful, the judgment may include . . . a civil penalty which shall not 20 exceed two times the amount of actual damages.” Cal. Civ. Code. § 1794(c). 21 However, “[t]he civil penalty under California Civil Code § 1794(c) cannot simply be 22 assumed.” Castillo v. FCA USA, LLC, No. 19-cv-151-CAB-MDD, 2019 WL 23 6607006, at *2 (S.D. Cal. Dec. 5. 2019).

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Ricardo Quiroz v. FCA US LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ricardo-quiroz-v-fca-us-llc-cacd-2023.