Mahesh Bhuta v. Toyota Motor Sales, U.S.A., Inc.
2:21-cv-07815
C.D. Cal.Nov 30, 2021Background
- Plaintiff Mahesh Bhuta sued Toyota in California state court alleging Song‑Beverly and Magnuson‑Moss Warranty Act (MMWA) claims arising from a leased 2018 Lexus LS 500 that allegedly failed to be repaired after a reasonable number of attempts.
- Toyota removed to federal court asserting federal question jurisdiction under the MMWA, which permits federal jurisdiction where the amount in controversy exceeds $50,000.
- Toyota’s notice of removal calculated the amount in controversy (actual damages plus civil penalty) at $211,684.05.
- Bhuta moved to remand, arguing Toyota failed to establish the amount in controversy required for federal diversity jurisdiction ($75,000).
- Bhuta elsewhere asserted a tangible damages claim of $70,561.35.
- The Court (Fitzgerald, J.) denied the motion to remand, concluding federal question jurisdiction under the MMWA was properly invoked because the amount in controversy exceeded $50,000.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether removal was improper for failure to meet amount in controversy | Bhuta: Toyota did not show amount in controversy exceeds $75,000 required for diversity jurisdiction | Toyota: Removal was under federal question jurisdiction (MMWA); MMWA threshold is $50,000 and Toyota’s calculation exceeds it ($211,684.05) | Court: Denied remand; federal question jurisdiction via MMWA satisfied because amount in controversy exceeds $50,000 |
Key Cases Cited
- Dart Cherokee Basin Operating Co. v. Owens, 547 U.S. 81 (2014) (plaintiff’s motion to remand requires defendant to show jurisdictional facts by preponderance)
- Rodriguez v. AT&T Mobility Servs., LLC, 728 F.3d 975 (9th Cir. 2013) (standards for establishing removability)
- Gaus v. Miles, Inc., 980 F.2d 564 (9th Cir. 1992) (ambiguities resolved in favor of remand but defendant bears burden of proof)
- Miller v. Grgurich, 763 F.2d 372 (9th Cir. 1985) (removability determined from complaint and removal notice at time of removal)
- Pacific Maritime Ass’n v. Mead, 246 F. Supp. 2d 1087 (N.D. Cal. 2003) (disputed jurisdictional facts resolved for remanding party)