Feichtmann v. FCA US LLC

Background

Jason Aaron Feichtmann sued FCA US LLC and South County Chrysler-Jeep-Dodge in state court. He alleged violations of California’s Song-Beverly Consumer Warranty Act, fraud, and negligent repair after purchasing a 2016 Jeep Cherokee manufactured by FCA. He alleged that the vehicle developed numerous defects and that South County’s repair efforts did not bring it into compliance with the warranties.

FCA removed the case to federal court under the diversity-jurisdiction statutes. Diversity jurisdiction generally requires that the parties be citizens of different states and that more than $75,000 be at stake. Feichtmann moved to remand, meaning he asked the federal court to return the case to state court. He argued that FCA had not established complete diversity or the required amount in controversy. FCA argued that South County was a sham defendant whose citizenship should be disregarded and that the claims placed more than $75,000 in controversy.

Amount in Controversy

The court held that FCA had not shown the required amount in controversy. Feichtmann’s complaint alleged damages of at least $25,001, but its request for relief separately listed actual damages, restitution, civil penalties, attorney’s fees, punitive damages, and other relief without stating one total amount. The court accepted Feichtmann’s explanation that the $25,001 figure represented the combined amount of actual damages and civil penalties.

Because the complaint did not clearly establish more than $75,000 in controversy, FCA had to prove by a preponderance of the evidence that at least an additional $50,000 was at stake. FCA relied only on a declaration from its counsel stating that attorney’s-fee awards in similar cases were regularly more than $100,000 and were typically at least $35,000. The court found that declaration unsupported by specific evidence and declined to rely on that estimate. The court therefore concluded that attorney’s fees could not establish the jurisdictional threshold.

Disposition

The court granted Feichtmann’s motion to remand. It stated that it did not need to decide whether complete diversity existed because the amount-in-controversy requirement was not satisfied. The Clerk of Court was directed to remand the action to Santa Clara County Superior Court and close the federal case.