770 F.3d 511
6th Cir.2014Background
- Plaintiffs purchased a 2180-square-foot, triple-wide manufactured home for $160,230 and defendant agreed to normal delivery and installation.
- Home delivered in three pieces; installation by one unlicensed worker per Tennessee law § 68-126-404(a).
- Plaintiffs noticed defects suggesting improper installation/leveling; defendant failed to repair/level the home for years.
- Plaintiffs sued in district court; asserted breach of contract and a federal breach of warranty under the Magnuson–Moss Warranty Act (MMWA).
- District court initially allowed the case to proceed under federal-question jurisdiction based on the MMWA claim; arbitration issues were considered but not dispositively resolved.
- Court ultimately held (1) jurisdiction exists; (2) the home is not a “consumer product” under MMWA; (3) the MMWA claim fails on the merits and is dismissed; (4) remand to address supplemental jurisdiction over remaining state-law claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the Bennetts’ home a consumer product under MMWA? | Bennetts argue home fits MMWA; broad definitions include fixtures | CMH contends home is real property/fixture not consumer product | Yes jurisdiction exists, but home is not a consumer product; MMWA claim fails on merits. |
| Does MMWA provide federal-question jurisdiction for this case? | Plaintiffs rely on MMWA to confer jurisdiction | Arbitration/attachment issues do not defeat jurisdiction | Court finds federal jurisdiction exists and proceeds to merits analysis. |
| Are the statutory text and history of MMWA consistent with treating manufactured homes as consumer products? | FTC/HUD interpretations treat manufactured homes as consumer products | Text excludes real property; modern homes not within scope | Court adopts FTC/HUD interpretations; manufactured home not a consumer product for MMWA. |
| Should the district court exercise supplemental jurisdiction over state-law claims after MMWA claim dismissal? | State-law claims remain appropriate for adjudication | Discretionary decision post-MMWA dismissal | Remand to district court to decide whether to exercise supplemental jurisdiction. |
Key Cases Cited
- Arbaugh v. Y&H Corp., 546 U.S. 500 (Supreme Court 2006) (subject-matter jurisdiction tied to a colorable federal claim; not all merits proofs required for jurisdiction)
- Gentek Bldg. Prods., Inc. v. Sherwin-Williams Co., 491 F.3d 320 (6th Cir. 2007) (jurisdiction can implicate an element of the claim; treat as merits issue when appropriate)
- Miller v. Herman, 600 F.3d 726 (7th Cir. 2010) (statutory interpretation of consumer-product definitions; applied to MMWA context)
- City Mgmt. Corp. v. U.S. Chem. Co., 43 F.3d 244 (6th Cir. 1994) (statutory interpretation and regulatory approach; may answer questions of law in first instance)
- Neague v. Cynkar, 258 F.3d 504 (6th Cir. 2001) (removal/withdrawal of supplemental jurisdiction considerations following dismissal)
- Orton v. Johnny’s Lunch Franchise, LLC, 668 F.3d 843 (6th Cir. 2012) (supplemental jurisdiction remains discretionary after federal claim dismissal)
- Schultz v. Gen. R.V. Ctr., 512 F.3d 754 (6th Cir. 2008) (burden on plaintiff to show amount in controversy satisfies $50,000 threshold)