William Gerald Barnett v. FCA US LLC

CourtDistrict Court, C.D. California
DecidedMay 18, 2020
Docket2:20-cv-03180
StatusUnknown

This text of William Gerald Barnett v. FCA US LLC (William Gerald Barnett 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
William Gerald Barnett v. FCA US LLC, (C.D. Cal. 2020).

Opinion

O 1 JS-6 2 3 4 5 6 7 United States District Court 8 Central District of California 9 10 11 WILLIAM GERALD BARNETT, SR. Case № 2:20-cv-03180-ODW (ASx) and DIANA T. BARNETT, 12 Plaintiffs, ORDER REMANDING ACTION 13 v. 14 FCA US LLC; H.W. HUNTER, INC.; 15 and DOES 1 through 10, inclusive, 16 Defendants. 17 18 I. INTRODUCTION 19 Plaintiffs William Gerald Barnett, Sr. and Diana T. Barnett (“Plaintiffs”) 20 initiated this action in the Superior Court of California, County of Los Angeles. 21 (Notice of Removal (“Notice”) ¶ 2, ECF No. 1; Decl. of Jennifer C. Koo, Ex. A 22 (“Compl.”), ECF No. 1-2.) Defendant FCA US LLC (“FCA”) removed the matter 23 based on alleged diversity jurisdiction. (See Notice at 3, 7.) After reviewing 24 Plaintiffs’ Complaint, FCA’s Notice of Removal, and the parties’ Responses to the 25 Court’s Order to Show Cause, the Court finds that it lacks subject matter jurisdiction 26 and consequently REMANDS this action.1 27

28 1 The Court deems the matter appropriate for sua sponte decision. United Inv’rs Life Ins. Co. v. Waddell & Reed Inc., 360 F.3d 960, 967 (9th Cir. 2004). 1 II. BACKGROUND 2 This is a Song-Beverly Consumer Warranty Act (“Song-Beverly”) action 3 concerning Plaintiffs’ 2017 Chrysler Pacifica, VIN 2C4RC1DG6HR653977 (the 4 “Vehicle”). (Compl. ¶ 8; Notice ¶ 16.) Plaintiffs allege the Vehicle “contained or 5 developed defects,” including with the Powertrain Control Module and a 6 “Transmission Defect.” (Compl. ¶¶ 10, 13.) On February 27, 2020, Plaintiffs filed 7 this action in the Superior Court of California, County of Los Angeles, Case 8 No. 20STCV08077. (See Compl.) Plaintiffs assert various causes of action against 9 FCA under Song-Beverly and for fraud by omission. (Compl. ¶¶ 26–57.) They also 10 assert claims against Defendant H.W. Hunter (“Hunter”) for breach of the implied 11 warranty of merchantability and negligent repair. (Compl. ¶¶ 45–49, 58–62.) 12 FCA removed the action based on alleged diversity jurisdiction. (See Notice 13 at 3, 7.) Plaintiffs appear to be California citizens. (See Compl. ¶ 2; Notice ¶ 27.) 14 FCA is a limited liability company organized under Delaware law with its principal 15 place of business in Michigan. (Compl. ¶ 4; Notice ¶ 28.) The membership-tree of 16 FCA’s limited liability company includes companies with citizenship in the 17 Netherlands and the United Kingdom. (See Notice ¶ 28.) Hunter is a California 18 entity2. (Compl. ¶ 5; Notice ¶ 30.) Accordingly, the Court ordered the parties to show 19 cause why the action should not be remanded for lack of diversity jurisdiction as it 20 appears Hunter is not diverse from Plaintiffs. (Min. Order, ECF No. 18.) The Court 21 has received and reviewed Plaintiffs’ and FCA’s responses. (See Pls.’ Resp., ECF 22 No. 22; FCA Resp., ECF No. 24.) 23 III. LEGAL STANDARD 24 Federal courts have subject matter jurisdiction only as authorized by the 25 Constitution and Congress. U.S. Const. art. III, § 2, cl. 1; see also Kokkonen v. 26 Guardian Life Ins. Co., 511 U.S. 375, 377 (1994). A suit filed in state court may be 27 removed to federal court only if the federal court would have had original jurisdiction 28 2 The parties offer no information as to what specific kind of legal entity Hunter is. 1 over the suit. 28 U.S.C. § 1441(a). Federal courts have original jurisdiction where an 2 action arises under federal law or where each plaintiff’s citizenship is diverse from 3 each defendant’s citizenship and the amount in controversy exceeds $75,000. Id. 4 §§ 1331, 1332(a). The removal statute is strictly construed against removal, and 5 “[f]ederal jurisdiction must be rejected if there is any doubt as to the right of removal 6 in the first instance.” Gaus v. Miles, Inc., 980 F.2d 564, 566 (9th Cir. 1992). The 7 party seeking removal bears the burden of establishing federal jurisdiction. Id. 8 Federal courts have a duty to examine their subject matter jurisdiction regardless of 9 whether the parties raise the issue. United Inv’rs Life Ins. Co., 360 F.3d at 966. The 10 court must remand the action “[i]f at any time before final judgment it appears that the 11 district court lacks subject matter jurisdiction.” 28 U.S.C. § 1447(c). 12 IV. DISCUSSION 13 FCA invokes diversity as the basis of the Court’s subject matter jurisdiction. 14 (See Notice at 3, 7.) The Supreme Court “ha[s] consistently interpreted § 1332 as 15 requiring complete diversity: In a case with multiple plaintiffs and multiple 16 defendants, the presence in the action of a single plaintiff from the same State as a 17 single defendant deprives the district court of original diversity jurisdiction over the 18 entire action.” Exxon Mobil Corp. v. Allapattah Servs., Inc., 545 U.S. 546, 553 19 (2005). Here, Plaintiffs allege that they are California citizens and that Hunter is a 20 California business entity. (Compl. ¶¶ 2, 5.) FCA agrees. (Notice ¶¶ 27, 30; FCA 21 Resp. 2–3.) Thus, complete diversity is destroyed. However, FCA argues that the 22 Court should disregard Hunter’s citizenship because Hunter was fraudulently joined. 23 (Notice ¶¶ 30–32; FCA Resp. 6–7.) The Court disagrees. 24 “An exception to the requirement of complete diversity exists where it appears 25 that a plaintiff has fraudulently joined a ‘sham’ non-diverse defendant.” Sanchez v. 26 Lane Bryant, Inc., 123 F. Supp. 3d 1238, 1241 (C.D. Cal. 2015). If a plaintiff 27 obviously fails to state a cause of action against a resident defendant according to the 28 settled rules of the state, “the joinder of the resident defendant is fraudulent.” 1 Hamilton Materials, Inc. v. Dow Chem. Corp., 494 F.3d 1203, 1206 (9th Cir. 2007) 2 (quoting McCabe v. Gen. Foods Corp., 811 F.2d 1336, 1339 (9th Cir. 1987)); see also 3 Padilla v. AT&T Corp., 697 F. Supp. 2d 1156, 1158 (C.D. Cal. 2009) (“[A] 4 non-diverse defendant is deemed a sham defendant if . . . the plaintiff could not 5 possibly recover against the party whose joinder is questioned.”). There is a general 6 presumption against fraudulent joinder and thus “[f]raudulent joinder must be proven 7 by clear and convincing evidence.” Hamilton Materials, 494 F.3d at 1206. 8 The standard for establishing fraudulent joinder is more exacting than for 9 dismissal for failure to state a claim. See Grancare, LLC v. Thrower by & through 10 Mills, 889 F.3d 543, 549–50 (9th Cir. 2018). If there is any “possibility that a state 11 court would find that the complaint states a cause of action against any of the resident 12 defendants, the federal court must find that the joinder was proper and remand the 13 case to the state court.” Id. at 549 (quoting Hunter v. Philip Morris USA, 582 F.3d 14 1039, 1046 (9th Cir. 2009)).

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

Related

Kokkonen v. Guardian Life Insurance Co. of America
511 U.S. 375 (Supreme Court, 1994)
National Ass'n of Manufacturers v. Taylor
582 F.3d 1 (D.C. Circuit, 2009)
Exxon Mobil Corp. v. Allapattah Services, Inc.
545 U.S. 546 (Supreme Court, 2005)
Burgess v. Superior Court
831 P.2d 1197 (California Supreme Court, 1992)
Hamilton Materials, Inc. v. Dow Chemical Corp.
494 F.3d 1203 (Ninth Circuit, 2007)
Padilla v. AT & T CORP.
697 F. Supp. 2d 1156 (C.D. California, 2009)
Sanchez v. Lane Bryant, Inc.
123 F. Supp. 3d 1238 (C.D. California, 2015)
Sabicer v. Ford Motor Co.
362 F. Supp. 3d 837 (C.D. California, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
William Gerald Barnett v. FCA US LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-gerald-barnett-v-fca-us-llc-cacd-2020.