Margo Nahmani v. Ford Motor Company
2:25-cv-04204
C.D. Cal.May 29, 2025Background
- Plaintiff Margo Nahmani filed suit against Ford Motor Company and others in state court.
- The case was removed by Ford Motor Company to federal court.
- Federal jurisdiction was alleged under a federal question (specifically, the Magnuson-Moss Warranty Act) and potentially diversity grounds.
- The Magnuson-Moss Warranty Act requires $50,000 or more in controversy, excluding costs and interest, to grant federal jurisdiction.
- The Notice of Removal did not provide sufficient evidence that the amount in controversy exceeded $50,000.
- The court sua sponte questioned its subject matter jurisdiction and issued an Order to Show Cause why the case should not be remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal jurisdiction is proper under MMA | Likely asserts jurisdiction not proper | Claims amount in controversy met | Court questions if threshold is met |
| Adequacy of allegations re: amount in controversy | Not specified | Provides notice, but no evidence | Defendant failed to show by preponder. |
| Standard for removal jurisdiction | Strictly construe against removal | Claims statute allows removal | Strict standard; doubt resolved against |
| Parties' burden on jurisdiction | Not specified | Defendant bears burden | Defendant must show sufficiency |
Key Cases Cited
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (federal courts have limited jurisdiction)
- DaimlerChrysler Corp. v. Cuno, 547 U.S. 332 (courts presumed to lack jurisdiction unless shown otherwise)
- Ruhrgas AG v. Marathon Oil Co., 526 U.S. 574 (court must examine jurisdiction sua sponte)
- Gaus v. Miles, Inc., 980 F.2d 564 (removal statute strictly construed; doubts resolved in favor of remand)
- Dart Cherokee Basin Operating Co. v. Owens, 574 U.S. 81 (removing party must allege and, if challenged, prove amount in controversy by preponderance of evidence)
- Leite v. Crane Co., 749 F.3d 1117 (court considers both facial and factual sufficiency of jurisdictional allegations)
