NGUYEN v. CHOICE HOME WARRANTY
1:24-cv-00844
| M.D.N.C. | Jan 30, 2025Background
- Minh Nguyen, a North Carolina resident, sued Choice Home Warranty, alleging breach of a home warranty contract.
- Plaintiff claims Defendant sent unlicensed workers to install a water heater, which then malfunctioned and was not repaired, resulting in lack of hot water.
- Plaintiff further alleges unsanitary home conditions and medical issues suffered by his wife due to the malfunction.
- The Complaint was filed pro se and accompanied by a request to proceed without prepaying fees (in forma pauperis).
- Plaintiff asserted diversity jurisdiction, alleging Defendant is incorporated in Delaware with its principal place of business in New Jersey.
- The Court reviewed the Complaint under 28 U.S.C. § 1915(e) for subject matter jurisdiction before granting any relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject Matter Jurisdiction (Diversity) | Parties are diverse by citizenship | Not available | Plaintiff failed to adequately plead Defendant’s business form or establish complete diversity |
| Amount in Controversy | Implied damages for home/wife’s health | Not available | Plaintiff failed to allege facts supporting >$75,000 in controversy |
| Relief (Legal Basis) | Breach of contract, damages implied | Not available | Only state law claims presented, insufficient for federal question jurisdiction |
| Consequential Damages | Medical issues consequential to breach | Not available | No facts showing such damages were foreseeable at time of contract |
Key Cases Cited
- Neitzke v. Williams, 490 U.S. 319 (1989) (defines when a complaint is considered 'frivolous' for IFP purposes)
- Hertz Corp. v. Friend, 559 U.S. 77 (2010) (federal courts have an independent obligation to determine subject-matter jurisdiction)
- Americold Realty Tr. v. Conagra Foods, Inc., 577 U.S. 378 (2016) (clarifies citizenship rules for business entities for diversity)
- St. Paul Mercury Indem. Co. v. Red Cab Co., 303 U.S. 283 (1938) (plaintiff must show legal certainty of exceeding jurisdictional amount)
- Hunt v. Washington State Apple Advert. Comm’n, 432 U.S. 333 (1977) (value of object of litigation governs jurisdictional amount for injunctions)