Thornton v. FCA US LLC
- Maxine Chesney
- 3:21-cv-04090
- U.S. District Court · Northern District of California
- 3
In Thornton v. FCA US LLC, Judge Chesney remanded the case to state court and denied FCA’s dismissal motion without prejudice because federal jurisdiction was not shown.
Patrick Thornton and FCA US LLC; the case was returned to California state court, where FCA may renew its motion to dismiss.
What happened
Patrick Thornton alleged that a vehicle he bought in 2018 had defects during its warranty period and that FCA US LLC could not repair it. He brought four California-law claims in state court, and FCA moved the case to federal court, asserting that the parties were citizens of different places and that more than $75,000 was at stake.
Thornton asked the federal court to return the case to state court, arguing that FCA had not shown he was a California citizen for purposes of federal jurisdiction. The court explained that the address Thornton gave in a 2018 sales contract did not establish where he was a citizen and permanently domiciled when he filed the case and when FCA moved it to federal court.
The court granted Thornton’s motion to remand and returned the case to California Superior Court in Lake County. Judge Maxine M. Chesney denied FCA’s motion to dismiss without prejudice to renewal in state court.
The detailed version
- Thornton v. FCA US LLC · No. 3:21-cv-04090
- Maxine Chesney
- July 27, 2021
Background
Patrick Thornton alleged that he purchased an FCA-manufactured vehicle in 2018, that the vehicle developed defects during the warranty period, and that FCA could not service or repair it. His complaint asserted four claims under California law and was initially filed in state court.
FCA removed the case to federal court on May 28, 2021. It argued that the parties had different citizenship and that the amount in dispute exceeded $75,000. FCA stated that Thornton was a citizen and resident of Lakeport, California, relying on a California address in a March 27, 2018, retail installment sale contract. FCA also stated that it was a citizen of the Netherlands and the United Kingdom through its ownership structure.
Jurisdiction and Remand
Thornton moved to remand, meaning he asked the federal court to return the case to state court. The court explained that because FCA was a citizen of foreign countries rather than a citizen of a U.S. state, the relevant diversity-jurisdiction provision covered cases between a U.S. state citizen and a foreign citizen or subject. For this purpose, Thornton had to be both a U.S. citizen and domiciled in a state. Domicile means a person’s permanent home, where the person lives with an intent to remain or intends to return.
The court held that the 2018 sales contract did not establish Thornton’s citizenship and domicile when he filed the complaint in April 2021 or when FCA removed the case in May 2021. Even assuming the California address showed that Thornton was then a U.S. citizen domiciled in California, more than three years had passed between the contract and the relevant filing and removal dates. FCA therefore failed to show that federal diversity jurisdiction existed.
Rulings
The court granted Thornton’s motion to remand and remanded the action to the Superior Court of the State of California in and for the County of Lake. It denied FCA’s motion to dismiss without prejudice to renewal in state court. The court also vacated the scheduled hearing and decided the motions based on the written submissions.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.