Adelfo Zatino Gutierrez v. General Motors, LLC et al.

Summary

The United States District Court for the Central District of California remanded the action to state court for lack of subject matter jurisdiction. The court held that General Motors had not established by a preponderance of the evidence that the amount in controversy exceeded $75,000 because its estimates of civil penalties and attorney’s fees were speculative.

Holdings

1. Defendant failed to establish that the amount in controversy exceeded $75,000 because its actual-damages estimate was below the threshold and its estimates of civil penalties and attorney's fees were speculative.

Questions Presented

1. Whether Defendant established that the amount in controversy exceeded $75,000 for purposes of diversity jurisdiction under 28 U.S.C. § 1332.
2. Whether the court should remand the action when Defendant's estimate of actual damages did not exceed $75,000 and its proposed civil penalties and attorney's fees were speculative.

Disposition

remanded