Russell Mullin v. FCA US LLC

CourtDistrict Court, C.D. California
DecidedMay 14, 2020
Docket2:20-cv-02061
StatusUnknown

This text of Russell Mullin v. FCA US LLC (Russell Mullin 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
Russell Mullin v. FCA US LLC, (C.D. Cal. 2020).

Opinion

1 O 2 JS6 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 12 RUSSELL MULLIN, ) CV 20-2061-RSWL-PJW ) 13 Plaintiff, ) ) ORDER re: Plaintiff’s 14 ) Motion to Remand [7] v. ) 15 ) ) 16 FCA US, LLC; SHAVER ) AUTOMOTIVE GROUP; and DOES ) 17 1 through 10, inclusive, ) ) 18 ) Defendants. ) 19 Plaintiff Russell Mullin (“Plaintiff”) brings this 20 Action against Defendant FCA US, LLC (“Defendant FCA”) 21 for violations of California’s Song-Beverly Consumer 22 Warranty Act (the “Song-Beverly Act”) and fraud by 23 omission and against Defendant Shaver Automotive Group 24 (“Defendant Shaver”) for claims of negligent repair 25 (collectively, “Defendants”). Currently before the 26 Court is Plaintiff’s Motion to Remand (“Motion”) [7]. 27 Having reviewed all papers submitted pertaining to the 28 1 Motion, the Court NOW FINDS AND RULES AS FOLLOWS: 2 GRANTS Plaintiff’s Motion. 3 I. BACKGROUND 4 A. Factual Background 5 Plaintiff alleges that Defendant FCA manufactured 6 and/or distributed a 2017 Chrysler Pacifica, Vehicle 7 Identification No. 2C4RC1BG1HR505819 (the “Vehicle”). 8 Ex. B to Decl. of Leon Roubinian in Supp. of Defs.’ 9 Notice of Removal, Compl. (“Compl.”) ¶ 8, ECF No. 1-3. 10 Plaintiff alleges that he purchased the Vehicle on May 11 16, 2016. Id. 12 Plaintiff alleges that during the Vehicle’s 13 warranty period, the Vehicle developed various defects, 14 including a transmission defect (the “Transmission 15 Defect”). Id. ¶ 16. Plaintiff further alleges that 16 Defendant FCA knew about the Transmission Defect since 17 2016, if not before, yet failed to mention it to its 18 sales representatives and its consumers, including 19 Plaintiff. Id. ¶ 17. 20 Additionally, Plaintiff alleges that he took the 21 Vehicle to Defendant Shaver, an automobile sales, 22 service, and repair business in Ventura County, for 23 “substantial repair on at least one occasion.” Id. ¶¶ 24 5, 59. Plaintiff maintains that Defendant Shaver 25 failed to “properly store, prepare, and repair the [] 26 Vehicle in accordance with industry standards.” Id. ¶ 27 61. 28 /// 1 B. Procedural Background 2 Plaintiff filed his Complaint [1-3] in Superior 3 Court of the State of California, County of Los 4 Angeles, on January 27, 2020, alleging violations of 5 the Song-Beverly Act and fraud by omission against 6 Defendant FCA and negligent repair against Defendant 7 Shaver. Defendants removed this Action to this Court 8 on March 2, 2020 [1]. Plaintiff filed the instant 9 Motion to Remand [7] on March 17, 2020. Defendants 10 filed their Opposition [8] on March 31, 2020, and 11 Plaintiff replied [11] on April 7, 2020. 12 II. DISCUSSION 13 A. Legal Standard 14 Civil actions may be removed from state court if 15 the federal court has original jurisdiction. See 16 Syngenta Crop Prot., Inc. v. Henson, 537 U.S. 28, 33 17 (2002) (“Under the plain terms of § 1441(a), in order 18 properly to remove [an] action pursuant to that 19 provision, . . . original subject-matter jurisdiction 20 [must] lie[] in the federal courts.”). Diversity 21 jurisdiction exists in all civil actions between 22 citizens of different states where the amount in 23 controversy exceeds $75,000, exclusive of interest and 24 costs. 28 U.S.C. § 1332. There must be complete 25 diversity of citizenship, meaning “each of the 26 plaintiffs must be a citizen of a different state than 27 each of the defendants.” Morris v. Princess Cruises, 28 Inc., 236 F.3d 1061, 1067 (9th Cir. 2001) (citing 1 Caterpillar Inc. v. Lewis, 519 U.S. 61, 68 (1996)). 2 Federal question jurisdiction exists in “all civil 3 actions arising under the Constitution, laws, or 4 treaties of the United States.” 28 U.S.C. § 1331. 5 “The burden of establishing jurisdiction falls on 6 the party invoking the removal statute, which is 7 strictly construed against removal.” Sullivan v. First 8 Affiliated Sec., Inc., 813 F.2d 1368, 1371 (9th Cir. 9 1987) (internal citations omitted). Courts resolve all 10 ambiguities “in favor of remand to state court.” 11 Hunter v. Philip Morris USA, 582 F.3d 1039, 1042 (9th 12 Cir. 2009) (citing Gaus v. Miles, Inc., 980 F.2d 564, 13 566 (9th Cir. 1992)). A removed case must be remanded 14 “[i]f at any time before final judgment it appears that 15 the district court lacks subject matter jurisdiction.” 16 28 U.S.C. § 1447(c). 17 B. Discussion 18 Plaintiff contends that this Court lacks subject 19 matter jurisdiction over this Action and so it should 20 be remanded to state court. The Court undisputably 21 lacks federal question jurisdiction; therefore, the 22 issue is whether the Court has diversity jurisdiction. 23 Thus, the burden is on Defendants to prove: (1) that 24 the amount in controversy exceeds $75,000; and (2) that 25 there is complete diversity of citizenship between the 26 parties. See Sullivan, 813 F.2d at 1371; 28 U.S.C. § 27 1332. 28 /// 1 1. Amount in Controversy 2 When a defendant removes a complaint to federal 3 court, the defendant’s burden with respect to the 4 amount in controversy varies depending on the 5 circumstances. Guglielmino v. McKee Foods Corp., 506 6 F.3d 696, 699 (9th Cir. 2007). But “where it is 7 unclear or ambiguous from the face of a state-court 8 complaint whether the requisite amount in controversy 9 is pled,” the applicable standard is by a preponderance 10 of the evidence; this requires that the defendant 11 offers evidence establishing that it is more likely 12 than not that the amount in controversy is met, 13 exclusive of costs and interest. Id. (citing Sanchez 14 v. Monumental Life Ins. Co., 102 F.3d 398, 404 (9th 15 Cir. 1996)). In considering whether the removing 16 defendant has satisfied its burden, the court “may 17 consider facts in the removal petition,” and 18 “‘summary-judgment-type evidence relevant to the amount 19 in controversy at the time of removal.’” Singer v. 20 State Farm Mut. Auto. Ins. Co., 116 F.3d 373, 377 (9th 21 Cir. 1997) (quoting Allen v. R & H Oil & Gas. Co., 63 22 F.3d 1326, 1335-36 (5th Cir. 1995)). 23 Here, Plaintiff’s Complaint alleges that he 24 “suffered damages in a sum to be proven at trial in an 25 amount that is not less than $25,001.00.” Compl. ¶ 11. 26 Thus, Plaintiff’s Complaint does not clearly indicate 27 that the $75,000 minimum amount in controversy is met. 28 Therefore, Defendants must establish by a preponderance 1 of the evidence that the jurisdictional minimum has 2 been satisfied. 3 a. Actual Damages 4 Plaintiff seeks to recover for Defendant FCA’s 5 violation of an express warranty under the Song-Beverly 6 Act, Cal Civ. Code § 1793.2. Actual damages under the 7 Song-Beverly Act are the “amount equal to the actual 8 price paid or payable by the buyer,” less the reduction 9 in value “directly attributable to use by the buyer.” 10 Cal. Civ. Code § 1793.2(d)(2)(B)-(C).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Caterpillar Inc. v. Lewis
519 U.S. 61 (Supreme Court, 1996)
Syngenta Crop Protection, Inc. v. Henson
537 U.S. 28 (Supreme Court, 2002)
United States v. Paul D. Wood
6 F.3d 692 (Tenth Circuit, 1993)
Hunter v. Philip Morris USA
582 F.3d 1039 (Ninth Circuit, 2009)
Conrad Associates v. Hartford Accident & Indemnity Co.
994 F. Supp. 1196 (N.D. California, 1998)
Brady v. Mercedes-Benz USA, Inc.
243 F. Supp. 2d 1004 (N.D. California, 2002)
Grant Fritsch v. Swift Transportation Co. of Az
899 F.3d 785 (Ninth Circuit, 2018)
Fagan v. City of Vineland
22 F.3d 1296 (Third Circuit, 1994)
Morris v. Princess Cruises, Inc.
236 F.3d 1061 (Ninth Circuit, 2001)

Cite This Page — Counsel Stack

Bluebook (online)
Russell Mullin v. FCA US LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/russell-mullin-v-fca-us-llc-cacd-2020.