Lange v. FCA US LLC
- William Alsup
- 3:20-cv-04266
- U.S. District Court · Northern District of California
- 1
Lange v. FCA US LLC: Judge Alsup denied remand because the amount in dispute likely exceeds $75,000, keeping the Lemon Law case in federal court.
Cari Lange and FCAUSLLC; the case remains in federal court rather than being returned to state court.
What happened
In Lange v. FCA US LLC, Cari Lange asked the court to send her individual, non-class automobile Lemon Law lawsuit back from federal court.
The court said the amount at stake could include about $30,000 for the car’s value after subtracting her use, twice that amount in civil penalties, and attorney’s fees. Because Lange would not agree that less than $75,000 was at issue, the court found enough money was involved for the case to remain in federal court.
Judge William Alsup denied the motion to remand. The court said a case-management scheduling order would follow and set September 11, 2020, at noon as the deadline for requests to modify the schedule.
The detailed version
- Lange v. FCA US LLC · No. 3:20-cv-04266
- William Alsup
- Aug. 27, 2020
Background
Cari Lange brought an individual, non-class automobile “Lemon Law” lawsuit against FCAUSLLC. She moved to remand, meaning she asked the federal court to return the case to state court. The opinion states that Lange did not name the in-state car dealership as a defendant, so the court focused on the amount in controversy.
Court’s Analysis
The court explained that federal jurisdiction based on diversity requires complete diversity between the parties and more than $75,000 in controversy. The amount in controversy may include the vehicle’s value minus the value of the plaintiff’s use, civil penalties for alleged willful conduct, and attorney’s fees. Here, the court estimated the vehicle-related amount at around $30,000, considered potential civil penalties equal to twice that amount, and included attorney’s fees. Because Lange refused to stipulate that the amount at issue was lower, the court found that more than $75,000 remained in dispute.
Ruling
The court denied Lange’s motion to remand. The case therefore remained in federal court. The court also stated that a case-management scheduling order would follow and gave the parties until September 11, 2020, at noon to seek schedule modifications.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.