Ayona v. Toyota Motor Sales, U.S.A., Inc.

Summary

The Central District of California denied Cynthia Ayona’s motion to remand her consumer warranty action against Toyota Motor Sales, U.S.A., Inc. The court held that removal was timely and that the amount-in-controversy requirement under the Magnuson-Moss Warranty Act was satisfied through potential Song-Beverly Act civil penalties and attorneys’ fees. The court also exercised supplemental jurisdiction over Ayona’s related state-law claims and vacated the hearing.

Holdings

1. Toyota's removal was timely because the last day of the thirty-day period is included when a time period is stated in days, and the April 3, 2025 notice of removal fell within the applicable period.
2. The action satisfied the Magnuson-Moss Warranty Act's $50,000 amount-in-controversy requirement.
3. The court exercised supplemental jurisdiction over Ayona's related state-law claims.
4. Ayona was not entitled to attorney fees under 28 U.S.C. § 1447(c).

Questions Presented

1. Whether Toyota timely removed the action within the applicable thirty-day removal period.
2. Whether the amount in controversy exceeded the Magnuson-Moss Warranty Act's $50,000 jurisdictional threshold.
3. Whether the court should decline supplemental jurisdiction over Ayona's related state-law claims.
4. Whether Ayona was entitled to attorney fees under 28 U.S.C. § 1447(c) based on the removal.

Disposition

remanded