Watson v. Masters Auto Recovery

Background

On November 12, 2025, Defendant GM Financial removed the action from the Supreme Court of New York, County of Bronx, to the U.S. District Court for the Southern District of New York. Plaintiff Shelton Watson moved to remand, meaning he asked the federal court to return the case to state court. GM opposed the motion.

Issues Identified by the Court

Watson argued that the action contains no federal claim. GM pointed to statements in Watson’s complaint alleging violations of constitutional rights protected by the United States and New York Constitutions, as well as references to the Federal Trade Commission Act, the Truth in Lending Act, and Regulation Z.

The court directed the parties to address the Supreme Court’s decision in Royal Canin U.S.A. Inc. et al. v. Wullschleger et al., which held that when an amendment removes the federal claims that allowed removal, the federal court loses supplemental jurisdiction over related state-law claims and the case must return to state court. The parties must specifically address whether Watson should clarify whether he asserts federal claims by filing an amended complaint, and whether the federal court has jurisdiction.

Order and Current Status

The order does not grant or deny Watson’s motion to remand. Instead, it directs the parties to be prepared to discuss these issues at a status conference scheduled for December 17, 2025, at 10:00 a.m. Judge Henry J. Ricardo also directed the Clerk of Court to mail a copy of the order to Watson, whom the order identifies as proceeding without a lawyer.