Sherrie R. Henderson v. General Motors, LLC

Background

Sherrie R. Henderson purchased a 2018 GMC Acadia in May 2018 for $66,934. She alleged that the vehicle was defective and that General Motors, LLC failed to fulfill its warranty obligations. She filed suit in Contra Costa County Superior Court on September 15, 2025, asserting claims under the Magnuson-Moss Warranty Act and the California Uniform Commercial Code.

The complaint did not request a specific dollar amount. GM transferred the case to federal court, asserting federal-question jurisdiction over the Magnuson-Moss claim and supplemental jurisdiction over Henderson’s remaining claim. Henderson moved to remand, meaning she asked the federal court to return the case to state court.

Legal Standard

The Magnuson-Moss Warranty Act allows federal lawsuits involving warranty claims, but federal jurisdiction requires more than $50,000 in dispute, excluding interest and costs. Because the complaint did not state a specific amount, GM had to show by a preponderance of the evidence—meaning that it was more likely than not—that the amount in controversy exceeded $50,000.

The amount in controversy is an estimate of the maximum amount reasonably at stake, not a prediction of what Henderson would ultimately win. The defendant bears the burden of establishing that amount.

Court’s Analysis

GM estimated damages using California Commercial Code section 2713. GM relied on the $66,934 purchase price, an estimated vehicle value of $24,480 when Henderson first presented it for repair, and at least $5,000 in incidental and consequential damages. GM also argued that attorney’s fees could be included.

The court determined that the $66,934 purchase price already included $10,167.30 in financing charges, so it did not use GM’s alternative estimate of $80,321.20. Even accepting GM’s other figures, the court calculated the amount in controversy as $66,934 minus $24,480 plus $5,000, or $47,454. The court did not include attorney’s fees because they were not automatically available under the Magnuson-Moss Warranty Act, and the other claim did not provide a state-law fee-shifting provision.

The opinion later states that the amount in controversy was $47,574, which conflicts with both the displayed calculation of $47,454 and the court’s conclusion that the amount was below $50,000.

Disposition

The court granted Henderson’s motion to remand and remanded the action to the County of Contra Costa Superior Court. The opinion did not state that the motion or case was dismissed, or that the remand was with or without prejudice.