Janette Ocegueda v. American Honda Motor Co., Inc.
2:23-cv-10870
C.D. Cal.Apr 2, 2024Background
- Plaintiffs Janette Ocegueda and others filed suit in California state court against American Honda Motor Co. and other defendants.
- Defendants removed the case to federal court, invoking federal subject matter jurisdiction.
- The court sua sponte questioned its jurisdiction, focusing on whether the amount in controversy exceeds $50,000, as required under the Magnuson-Moss Warranty Act (MMWA).
- The removal notice failed to plausibly demonstrate the necessary amount in controversy under federal law.
- Parties were ordered to show cause, within 14 days, why the case should not be remanded for lack of subject matter jurisdiction, specifically on the amount in controversy issue.
- Failure of the defendant to respond adequately will result in automatic remand to state court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the amount in controversy exceed $50,000 under MMWA? | (Implied: Amount is under $50,000) | Removal is proper; controversy >$50k | Defendant has not shown by preponderance the amount met |
| Is federal jurisdiction proper under removal statute? | Likely challenges federal jurisdiction | Federal court has original jurisdiction | Court doubts jurisdiction, orders show cause |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (federal courts have limited jurisdiction and must be affirmatively demonstrated)
- DaimlerChrysler Corp. v. Cuno, 547 U.S. 332 (jurisdiction must be shown clearly in the record)
- Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574 (court must examine jurisdiction before merits)
- Gaus v. Miles, Inc., 980 F.2d 564 (removal statutes construed strictly against removal)
- Dart Cherokee Basin Operating Co., LLC v. Owens, 574 U.S. 81 (burden on removing party to show amount in controversy).
- Leite v. Crane Co., 749 F.3d 1117 (court evaluates both facial and factual sufficiency of amount in controversy).