Scott v. Ford Motor Company
- Edward Davila
- 5:21-cv-06418
- U.S. District Court · Northern District of California
- 7
In Scott v. Ford Motor Company, Judge Davila denied Scott’s motion to remand, finding diversity jurisdiction and more than $75,000 in controversy.
Karen R. Scott and Ford Motor Company; the case remains in federal court rather than returning to California state court.
What happened
In Scott v. Ford Motor Company, Karen R. Scott sued Ford Motor Company in California state court over alleged defects in a Ford F-150 and claims under California’s consumer warranty law. After Susanville Ford was dismissed from the state case, Ford moved the case to federal court, and Scott asked the federal court to send it back to state court.
Scott argued that Ford had not shown that more than $75,000 was at stake. The court disagreed, relying on the complaint’s allegations that the vehicle cost $50,567.16, Scott sought the entire contract price, and she requested a civil penalty equal to twice her actual damages. Together, those allegations put nearly $150,000 in dispute.
The court denied Scott’s motion to remand and kept the case in federal court. Judge Davila ruled that the requirements for federal jurisdiction based on different-state parties and the amount in controversy were satisfied.
The detailed version
- Scott v. Ford Motor Company · No. 5:21-cv-06418
- Edward Davila
- Apr. 18, 2022
Background
Karen R. Scott filed this action in California state court against Ford Motor Company and Susanville Ford, asserting claims for breach of implied and express warranties under California’s Song-Beverly Consumer Warranty Act. Scott alleged that she purchased a 2016 Ford F-150 from Susanville Ford for approximately $50,567.16, that the vehicle developed defects during the warranty period, and that Ford and its California representatives could not repair the vehicle after a reasonable number of opportunities. She also alleged that Ford did not replace the vehicle or provide restitution.
Scott voluntarily dismissed Susanville Ford from the state case. Ford then removed the action to federal court based on diversity jurisdiction, which allows federal courts to hear certain cases involving parties from different states when more than $75,000 is in controversy. Scott moved to remand, arguing that Ford had not established the required amount in controversy. She did not contest that complete diversity existed.
Court’s Analysis
The court explained that the removing party bears the burden of establishing federal jurisdiction. When a state-court complaint itself alleges an amount sufficient to meet the jurisdictional threshold, that amount is presumptively satisfied unless it is legally certain that the plaintiff cannot recover it.
The complaint alleged that the vehicle’s sales price was approximately $50,567.16 and that Scott sought the entire contract price as a remedy. It also requested a civil penalty of two times her actual damages under California Civil Code section 1794. The court treated both the contract price and the requested civil penalty as amounts Scott had placed in controversy. It therefore concluded that the complaint put an amount approaching $150,000 in controversy, well above the $75,000 threshold.
The court did not reach the separate analysis of whether Ford’s evidence would have established the amount in controversy by a preponderance of the evidence. It also did not reduce the alleged contract price for a mileage offset because the complaint sought the entire contract price and did not allege an offset.
Disposition
The court found that the diversity and amount-in-controversy requirements for subject-matter jurisdiction under 28 U.S.C. § 1332(a) were satisfied. Judge Edward J. Davila denied Scott’s motion to remand. The opinion did not decide the underlying warranty claims.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.