Wang v. BMW of North America, LLC

Background

Wang brought a lemon-law action against BMW of North America, LLC in state superior court. The case was removed to federal court, and Wang moved to remand it, meaning he asked the federal court to return it to state court.

Reasons for the Decision

The court held that it had diversity jurisdiction. Diversity jurisdiction allows a federal court to hear certain state-law cases when the opposing parties are citizens of different states and more than $75,000 is in controversy.

The complaint valued Wang’s damages at not less than $25,000 and sought a civil penalty of twice his actual damages. The court calculated those amounts as $25,000 in damages plus $50,000 in potential civil penalties, for a total of $75,000. The complaint also requested attorney’s fees. Because even one penny in attorney’s fees would raise the amount above $75,000, the court found the amount-in-controversy requirement satisfied.

The court also found that the parties had different citizenship. BMW of North America is an LLC whose sole member is BMW (US) Holding Corporation. That corporation is incorporated in Delaware and has its principal place of business in New Jersey. The court found that BMW had shown, by more likely than not, that Wang was a California citizen. It relied on Wang’s California address in a 2018 purchase agreement and a 2020 customer-service report, as well as evidence that Wang had held a California driver’s license since 2019, had a California telephone area code, and had been associated with six California addresses since 2017. The court said the citizenship of unidentified “Doe” defendants did not matter to the jurisdiction analysis.

The court rejected Wang’s argument that it could decline to exercise diversity jurisdiction. It explained that the Supreme Court decision Wang cited concerned federal-question jurisdiction, not diversity jurisdiction.

Ruling

Judge Vince Chhabria denied Wang’s motion to remand. The opinion did not decide the underlying lemon-law claims.