Miller, Jr. v. Ford Motor Company

Background

Robert A. Miller, Jr. sued Ford Motor Company and Gosch Auto Group, Inc. after purchasing a 2016 Ford Fusion with an express written warranty and bringing the vehicle to Gosch for service and repair. Miller alleged that the vehicle was not brought into compliance with the applicable warranties. His amended complaint asserted one claim against Ford under the Magnuson-Moss Warranty Act and one negligent-repair claim against Gosch. He sought damages, restitution, consequential and incidental damages, remedies under the Magnuson-Moss Warranty Act, prejudgment interest, and other relief. He alleged damages of an amount not less than $25,001 and did not claim punitive damages.

Ford removed the case from Santa Clara County Superior Court to federal court, asserting federal-question jurisdiction based on the Magnuson-Moss Warranty Act, supplemental jurisdiction over related state claims, and diversity jurisdiction based on fraudulent joinder. Miller moved to remand. Ford did not oppose the motion.

Federal-question jurisdiction

The Magnuson-Moss Warranty Act limits federal-court claims when the amount in controversy for all claims in the action is less than $50,000, excluding interest and costs. The court explained that the party seeking removal bears the burden of establishing federal jurisdiction.

The court found that Ford had not shown the amount in controversy met that threshold. Miller’s allegation of damages of “a sum to be proven in trial in an amount that is not less than $25,001.00” was speculative because it appeared only once and used ambiguous language. The court also noted that Miller’s amended complaint no longer sought civil penalties under the California Song-Beverly Consumer Warranty Act, and that Ford relied on the vehicle’s purchase price without accounting for factors such as the vehicle’s use or other adjustments. The court therefore found Ford’s showing inadequate to satisfy the Magnuson-Moss Warranty Act’s $50,000 requirement.

Diversity jurisdiction

The court stated that, because it could not establish that Miller’s claim satisfied the $50,000 federal warranty threshold, Ford also could not prove by a preponderance of the evidence that the amount in controversy exceeded $75,000 for diversity jurisdiction. The court therefore did not address Ford’s fraudulent-joinder argument concerning Gosch.

Disposition

The court granted Miller’s motion to remand. It remanded the case to the Superior Court of California for the County of Santa Clara and ordered the Clerk to close the federal case.