Sergio Zamora v. Ford Motor Company

CourtDistrict Court, C.D. California
DecidedJanuary 17, 2025
Docket2:24-cv-09850
StatusUnknown

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Bluebook
Sergio Zamora v. Ford Motor Company, (C.D. Cal. 2025).

Opinion

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA JS-6 CIVIL MINUTES - GENERAL Case No. CV 24-9850 FMO (PDx) Date January 17, 2025 Title Sergio Zamora v. Ford Motor Company

Present: The Honorable Fernando M. Olguin, United States District Judge Vanessa Figueroa None None Deputy Clerk Court Reporter / Recorder Tape No. Attorney Present for Plaintiff(s): Attorney Present for Defendant(s): None Present None Present Proceedings: (In Chambers) Order Re: Motion to Remand On July 23, 2024, Sergio Zamora (“plaintiff”) filed a complaint in the Los Angeles County Superior Court (“state court’) against Ford Motor Company (“defendant”), asserting breach of warranty claims under the California Song-Beverly Consumer Warranty Act, (“Song-Beverly Act”), Cal. Civ. Code § 1790, et seg. (See Dkt. 1, Notice of Removal (“NOR”) at J 1); (Dkt. 1-2, Complaint). On November 14, 2024, defendant removed the action on the basis of diversity jurisdiction. (See Dkt. 1, NOR at 2). Plaintiff now seeks remand on the basis that removal was untimely. (See Dkt. 13, Motion to Remand (“Motion”) at 2); (id., Memorandum of Points and Authorities (“Memo.”) at 1). Having reviewed the pleadings and the briefing filed with respect to plaintiff's Motion, the court finds that oral argument is not necessary to resolve the Motion, see Fed. R. Civ. P. 78(b); Local Rule 7-15; Willis v. Pac. Mar. Ass'n, 244 F.3d 675, 684 n. 2 (9th Cir. 2001), and concludes as follows. LEGAL STANDARD “Federal courts are courts of limited jurisdiction. They possess only that power authorized by Constitution and statute[.]” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377, 114 S.Ct. 1673, 1675 (1994). “The right of removal is entirely a creature of statute and a suit commenced in a state court must remain there until cause is shown for its transfer under some act of Congress.” Syngenta Crop Protection, Inc. v. Henson, 537 U.S. 28, 32, 123 S.Ct. 366, 369 (2002) (internal quotation marks omitted). Where Congress has acted to create a right of removal, those statutes, unless otherwise stated, are strictly construed against removal jurisdiction.’ See id. Unless otherwise expressly provided by Congress, “any civil action brought in a State court of which the district courts of the United States have original jurisdiction, may be removed by the defendant or the defendants, to the district court[.]” 28 U.S.C. § 1441(a); see Dennis v. Hart, 724

' For example, an “antiremoval presumption” does not exist in cases removed pursuant to the Class Action Fairness Act (“CAFA”), 28 U.S.C. § 1332(d). See Dart Cherokee Basin

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA JS-6 CIVIL MINUTES - GENERAL Case No. CV 24-9850 FMO (PDx) Date January 17, 2025 Title Sergio Zamora v. Ford Motor Company F.3d 1249, 1252 (9th Cir. 2013) (same). A removing defendant bears the burden of establishing that removal is proper. See Abrego Abrego v. The Dow Chem. Co., 443 F.3d 676, 684 (9th Cir. 2006) (per curiam) (noting the “longstanding, near-canonical rule that the burden on removal rests with the removing defendant’); Gaus v. Miles, Inc., 980 F.2d 564, 566 (9th Cir. 1992) (“The strong presumption against removal jurisdiction means that the defendant always has the burden of establishing that removal is proper.”) (internal quotation marks omitted). DISCUSSION Section 1446(b)(1) of Title 28 of the United States Code’ requires a defendant to remove a case “within 30 days after the receipt by the defendant, through service or otherwise, of a copy of the initial pleading setting forth the claim for relief upon which such action or proceeding is based[.]” This 30-day removal period “is triggered if the case stated by the initial pleading is removable on its face.” Kuxhausen v. BMW Financial Services NALLC, 707 F.3d 1136, 1139 (9th Cir. 2013) (internal quotation marks omitted). In other words, “the ground for removal must be revealed affirmatively in the initial pleading in order for the first thirty-day clock under § 1446(b) to begin.” Id. (internal quotation marks omitted). However, “if the case stated by the initial pleading is not removable, a notice of removal may be filed within 30 days after receipt by the defendant, through service or otherwise, of a copy of an amended pleading, motion, order or other paper from which it may first be ascertained that the case is one which is or has become removable.” 28 U.S.C. § 1446(b)(3). While the 30-day time limit is procedural rather than jurisdictional, “the time limit is mandatory and a timely objection to a late petition will defeat removall[.]” Smith v. Mylan, Inc., 761 F.3d 1042, 1045 (9th Cir. 2014) (internal quotation marks omitted). Indeed, the statutory removal deadline “must be strictly complied with, and is to be narrowly construed.” United States ex rel. Walker v. Gunn, 511 F.2d 1024, 1026 (9th Cir. 1975); Kang v. Allied Consultants, Inc., 2021 WL 1010629, *1 (C.D. Cal. 2021) (same). Here, defendant removed the action on November 14, 2024. (See Dkt. 1, NOR). Although the NOR did not specify when defendant was served with the Complaint, (see, generally, id. at □ 2), defendant represented that removal was timely because plaintiff's responses to discovery, which were served on October 15, 2024, admitted for the first time the amount in controversy and plaintiff's citizenship. (See id.). Plaintiff contends that, contrary to defendant’s representations, “removability of this action was clear and ascertainable from the fact of plaintiff's State Complaint.” (Dkt. 13, Memo. at 1). And because defendant was served with the Complaint and Summons on August 1, 2024, its November 14, 2024, removal was untimely. (See id. 3-4). The court agrees with plaintiff. While defendant relies on the second removal period under § 1446(b)(3), (see Dkt. 1, NOR at ¥ 2), it is clear that plaintiffs Complaint triggered the first removal period under § 1446(b)(1).

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UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA JS-6 CIVIL MINUTES - GENERAL Case No. CV 24-9850 FMO (PDx) Date January 17, 2025 Title Sergio Zamora v. Ford Motor Company With respect to the amount in controversy, the NOR stated that the Complaint “was not facially removable as plaintiff failed to plead an amount in controversy in excess of $75,000.” (Dkt. 1, NOR at J 2); (See also Dkt. 15, Defendant’s Opposition to Plaintiff's Motion to Remand (“Opp”) at 5). According to defendant, it wasn’t until plaintiff served his discovery responses that plaintiff “admitted” that “he was seeking more than $75,000 in damages.” (Dkt. 1, NOR at J] 2, 12).

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Sergio Zamora v. Ford Motor Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sergio-zamora-v-ford-motor-company-cacd-2025.