Lien v. Mercedes-Benz USA, LLC

Background

Phat T. Lien sued Mercedes-Benz USA, LLC based on his purchase of a used Mercedes-Benz vehicle. His claims were for breach of express warranty, breach of implied warranty, breach of the implied covenant of good faith and fair dealing, and violations of the Magnuson-Moss Warranty Act.

Mercedes-Benz moved for summary judgment, which is a request to rule for the moving party because the evidence does not require a trial. Lien did not oppose the motion as to his implied-warranty, good-faith-and-fair-dealing, and Magnuson-Moss claims. The court therefore found that Lien had abandoned those claims and entered summary judgment for Mercedes-Benz on them.

Federal Jurisdiction

The court concluded that federal jurisdiction over Lien’s amended complaint was initially proper. Lien had asserted a facially viable claim under the federal Magnuson-Moss Warranty Act, supporting federal-question jurisdiction. The court also noted that the alleged vehicle value was $60,459.80 and that the attorney-fee request under the Magnuson-Moss Act could have brought the amount in controversy above the $75,000 threshold for diversity jurisdiction.

After the three claims were resolved, the express-warranty claim was the only remaining claim. That claim arose under California Commercial Code § 2313, so federal-question jurisdiction did not apply. The court also found that Mercedes-Benz had not shown that the amount in controversy for that claim exceeded the jurisdictional threshold. The court therefore determined that its jurisdiction over the express-warranty claim was supplemental jurisdiction, meaning jurisdiction over a state-law claim connected to claims within the court’s original jurisdiction.

Ruling

The court declined to continue exercising supplemental jurisdiction under 28 U.S.C. § 1367(c)(3). It explained that there had been no litigation on the merits of the express-warranty claim and that state courts were better equipped to resolve the remaining state-law issues. The court granted Mercedes-Benz’s motion for summary judgment as to Lien’s implied-warranty, good-faith-and-fair-dealing, and Magnuson-Moss claims, declined to exercise supplemental jurisdiction over the remaining express-warranty claim, and remanded the action to the Superior Court of California for the County of San Francisco.