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Margo Nahmani v. Ford Motor Company
2:25-cv-04204
C.D. Cal.
May 29, 2025
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Background

  • 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)
Read the full case

Case Details

Case Name: Margo Nahmani v. Ford Motor Company
Court Name: District Court, C.D. California
Date Published: May 29, 2025
Docket Number: 2:25-cv-04204
Court Abbreviation: C.D. Cal.